State v. Stanley, 2016 Ohio 1540

Nathaniel L. Stanley pled guilty (Aug 2, 2013) in two Cuyahoga County cases to multiple drug-possession/trafficking felonies with forfeiture specs.
On Oct 16, 2013 the trial court sentenced Stanley to one year of community control (including six months in a community-based correctional facility) and warned that violations could result in up to 3.5 years’ imprisonment. Costs were imposed.
Docket entries filed Sept 24, 2014 stated Stanley’s supervision was extended to April 16, 2015 to allow completion of community work service (CCWS) and an intensive outpatient program (IOP); no hearing or written waiver appears in the record.
Stanley continued to report to probation and make partial payments after the original one-year term expired and did not appeal or object to the extension.
A community-control-violation hearing was held Jan 13, 2015: the court found Stanley violated treatment/testing requirements and sentenced him to 2.5 years in prison (plus 30 days for misconduct during the hearing).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Stanley)	Held
Whether the court’s September 24, 2014 extension of community control was invalid for lack of notice/hearing	Extension was effective because defendant acquiesced and continued to report and pay, so court retained jurisdiction to revoke	The journal entry extending supervision was void ab initio because there was no hearing/notice, so court lost jurisdiction to impose prison after the original one-year term expired	Court held extension was not invalid: Stanley waived objection by acquiescing (continuing to report/pay) and failing to appeal; revocation and prison sentence were proper

Forgues v. United States, 636 F.2d 1125 (6th Cir. 1980) (probation-extension procedures need not mirror revocation due-process protections)
State v. Criss, 55 Ohio App.3d 238 (8th Dist. 1988) (trial court may extend probation without a hearing for nonpayment of court costs)