State v. Tidd, 2012 Ohio 4982

Tidd pled guilty to Theft in exchange for dismissal of a Receiving Stolen Property count, pursuant to an indictment with Dingle and Tidd.
Trial court imposed 13 community control sanctions for up to five years, including supervision, fees/restitution, treatment, employment, no-contact with co-defendants, and library restrictions.
On August 5, 2011, the court suspended probation due to alleged absconding and failure to report; capias issued for Tidd.
On October 11, 2011, after a revocation hearing, the court continued Tidd on community control but added sanctions: 60 days in jail and YES Program completion.
On November 15, 2011, the court revoked community control and sentenced Tidd to nine months in prison; she appeals claiming abuse of discretion, hearsay at the second revocation, and reliance on pre-imposition conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is moot	Tidd's appeal targets revocation discretion; relief available is nonexistent since sentence served.	Court should consider merits; potential collateral effects persist if not moot.	Moot; dismissed
Whether revocation was improper based on conduct known before original sentence or after but before first hearing	Revocation relied on conduct outside proper temporal bounds.	Court acted within discretion based on probation history and conduct.	Moot; dismissed

State v. Bell, 2011-Ohio-6799 (2d Dist. Montgomery 2011) (appeal from revocation and imposed sentence moot when sentence completed)
State v. Orr, 2009-Ohio-5515 (11th Dist. Geauga 2009) (collateral disability argument for non-mootness not adopted here)
State v. Smith, 2002-Ohio-1330 (11th Dist. Lake 2002) (pure sentence appeal moot if sentence completed)