State v. Baker — Court of Appeals affirms prison sentence for community-control violation

Case
State of Ohio v. Raymond Baker, Jr.
Court
Ohio Court of Appeals, Eighth District, Cuyahoga County
Judge
Michael John Ryan, P.J.; Deena R. Calabrese, J.; Timothy W. Clary, J.
Date Decided
October 15, 2026
Docket No.
116094
Topics
Community control; Sentencing; Prison terms; Criminal appeal
Source
Read the full opinion

Background

Raymond Baker Jr. pleaded guilty to having weapons while under disability, a third-degree felony, and aggravated menacing, a first-degree misdemeanor. The trial court imposed community-control sanctions.

At the original sentencing hearing, the court told Baker that violating community control could result in jail or prison and that a prison term could range from 9 to 36 months. After Baker admitted violating community control, the court imposed concurrent terms of 18 months on the felony and 180 days on the misdemeanor.

The Court’s Holding

The Eighth District affirmed. It held that the trial court complied with R.C. 2929.19(B)(4) because, at the community-control sentencing hearing, it advised Baker that a violation could result in prison and stated the applicable 9-to-36-month range.

Baker’s reliance on cases requiring more particular notice did not change the result. Those decisions involved either the former statute, which required notice of a specific prison term, inadequate notice at the original sentencing hearing, or consecutive sentences. The current statute required notice of the range, which Baker received.

Key Takeaways

  • A court may impose prison after a community-control violation when it gave the required notice at the original sentencing hearing.
  • Under R.C. 2929.19(B)(4), the court must identify the applicable prison-term range; it need not reserve a specific term.
  • Notice in a journal entry alone cannot cure a failure to give required notice at sentencing.

Why It Matters

The decision distinguishes Ohio’s current range-notice requirement for community control from earlier law requiring a specific reserved prison term. It also confirms that an adequate oral sentencing advisement supports a later prison sentence for a community-control violation.

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