State v. Thompson, 950 N.E.2d 1022

Thompson was charged in Franklin County with multiple counts related to sexual offenses arising from acts committed against the same victims.
In 2002, Thompson entered a guilty plea to three counts of gross sexual imposition and one count of sexual battery; the court sentenced him to four years for sexual battery and five years of community control on the gross-imposition counts to be served after the prison term.
The sentencing included an oral warning that violations of community control could lead to additional or consecutive imprisonment, potentially 18 months per count, if violated.
The judgment entry later stated that the court “may impose” an 18-month sentence for each count upon violation, using permissive language rather than definite terms.
In 2010, Thompson’s probation was revoked for violating community control; the court imposed 12-month prison terms on each gross-imposition count, to run consecutively to each other and to the Pickaway County sentence.
Thompson appealed, arguing the journal entry failed to notify him of the specific prison term to be imposed for a community-control violation, as required by R.C. 2929.19(B)(5) and Brooks.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether journal-entry notice satisfied statutory Brooks requirements	Thompson argues the entry’s ‘may impose’ language failed to specify a definite term.	State contends oral notification at sentencing satisfied Brooks; journal entry need not repeat a fixed term.	Notification satisfied Brooks; entry was sufficient.

Brooks v. Ohio, 103 Ohio St.3d 134 (Ohio Supreme Court, 2004) (requires detailed at-sentencing notification of a specific term for community-control violations; journal entries after sentencing do not suffice)