State v. Tackett, 2019 Ohio 2253

Brooke A. Tackett was sentenced (March 30, 2017) to 4 years of community control with a previously suspended 22‑month prison term for multiple felony offenses (possession of heroin, receiving stolen property, theft, forgery, complicity to commit theft).
Community control conditions included reporting to probation, obeying laws, no drug use, submitting to tests, and maintaining employment.
Probable cause letter (May 30, 2018) alleged seven violations: failure to report biweekly (absconding), new charges (identity theft/forgery), extensive missed drug calls/tests, two positive drug tests, failure to comply with drug‑testing program, failure to obtain/maintain employment, and failure to show job‑search proof.
At the June 25, 2018 hearing Tackett admitted the violations and the court explained her rights; counsel argued one basis (the new felony charges) had been dismissed in municipal court and R.C. 2929.15(B)(1)(c)(i) therefore limited prison time to 90 days.
The trial court revoked community control and imposed the previously suspended 22‑month prison term; Tackett appealed, claiming the sentence exceeded the 90‑day statutory limit for technical violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2929.15(B)(1)(c)(i) limited Tackett to 90 days because violations were technical	Tackett: violations were technical (administrative) so statute caps prison for technical violations at 90 days	State: violations were non‑technical (criminal or substantive rehabilitative) so full suspended term may be imposed	Court held violations were non‑technical (absconding, new charges, missed/positive drug tests, failure to seek/maintain employment); 22‑month term lawful

(There are no key authorities in this opinion with official reporter citations.)