State v. Walsson, 2018 Ohio 4485

Defendant Raymond W. Walsson pleaded guilty to three fifth-degree felonies and was placed on five years of community control.
Probation filed an affidavit alleging multiple violations (failure to follow laws, drug/alcohol use, failure to complete treatment, failure to pay costs/fees/restitution).
Walsson admitted to violations at two hearings; the court found violations including use of heroin and cocaine.
The trial court revoked community control and sentenced Walsson to three consecutive eight-month terms.
The court reasoned R.C. 2929.15(B)(1)(c)(i)’s 90-day cap did not apply because Walsson (a) was on community control for three separate offenses and (b) committed new felony offenses (drug use) while under supervision.
Walsson appealed, arguing the 90-day limitation should apply and his sentence is contrary to law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2929.15(B)(1)(c)(i)’s 90-day cap applies to revocation when community control was imposed for multiple fifth-degree felonies	State: cap inapplicable where defendant committed new felony offenses while under supervision	Walsson: 90-day statutory limitation applies despite multiple underlying fifth-degree felonies	Held: 90-day cap inapplicable because Walsson committed new felony offenses (possession/use of heroin and cocaine) while on community control; sentence affirmed

State v. Marcum, 146 Ohio St.3d 516 (2016) (standard of appellate review for felony sentences under R.C. 2953.08(G)(2))