State v. Schafer, 2014 Ohio 5814

Diana Schafer pleaded guilty to three Akron housing-code violations as part of a plea agreement; seven other counts were dismissed.
At plea, the court imposed for each count a $500 fine and 60 days jail, but suspended $400 of the fine and all jail time on conditions: obey laws for one year, complete interior repairs by Feb. 1, 2013 (with inspection), and complete exterior repairs by July 1, 2013 (with inspection).
The court held the sentence in abeyance to allow Schafer time to comply; the written journal entry reflected the conditional suspension terms.
Schafer failed to complete the required repairs despite extensions; at a November 20, 2013 status hearing the court imposed a total $1,500 fine and six months probation, and ordered compliance with the original conditions.
Schafer appealed, arguing the court increased her sentence beyond the plea agreement and violated due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court increased Schafer's sentence beyond the plea agreement	Schafer contends she was not put on notice she could receive more than a $100 fine and that the court increased the agreed sentence	The City and trial court argue the plea and oral/written sentencing terms put Schafer on notice she would receive $500 and 60 days jail per count if she failed to comply; Schafer failed to satisfy the conditions so she lost the benefit of the suspended portions	Court held the sentence was not increased: plea and journal entry warned of $500/60-day penalties per count if conditions not met; because Schafer breached the agreement, she was not entitled to the lesser sentence; but remanded to correct an unlawful $1,500 fine entry that misapplied the fine to a single count

State v. Bethel, 110 Ohio St.3d 416 (principles of contract law apply to plea agreements)
Wooster v. Entertainment One, Inc., 158 Ohio App.3d 161 (law will not reward a breaching party)