State v. Scott, 2017 Ohio 4100

Donald F. Scott was indicted on four counts of felonious assault; he pled no contest to two counts and was sentenced to community control (up to five years).
The judgment entry warned Scott could receive prison terms if he violated community control.
Multiple notices of community-control revocation were filed after alleged violations (new criminal charges, failure to appear, missed probation reporting, missed child support, failure to verify community service).
At the revocation proceeding Scott admitted he violated Rule 5 (failure to appear/report) and admitted aspects of Rule 1 (challenged some charge accuracy), and counsel presented mitigation.
The trial court orally stated its reasons on the record, revoked community control, and sentenced Scott to three years’ imprisonment on each count (concurrent). A written termination entry followed; the hearing was transcribed.

Issue	State's Argument	Scott's Argument	Held
Whether the trial court satisfied Gagnon’s requirement that the factfinder provide a written statement of the evidence relied on and reasons for revocation	State: the combination of the court’s oral on-the-record explanation, the written transcript of the hearing, and the subsequent written judgment entry satisfied Gagnon	Scott: absence of a separate written statement setting out the evidence and reasons deprived him of due process	Court: Affirmed — oral findings on the record, transcript, Scott’s admission, and written judgment entry satisfied the written-statement requirement under Gagnon and Delaney

Gagnon v. Scarpelli, 411 U.S. 778 (1973) (sets due-process protections for probation/parole revocation proceedings)
Morrissey v. Brewer, 408 U.S. 471 (1972) (articulates procedural safeguards for parole revocation hearings)
State v. Delaney, 11 Ohio St.3d 231 (1984) (Ohio Supreme Court: oral findings on the record may satisfy Gagnon where the record adequately informs the defendant and permits appellate review)