State v. Green — Second District affirms community-control revocation and 14-month sentence

Case
State of Ohio v. Anthony Quinn Green
Court
Ohio Court of Appeals, Second District
Judge
Michael L. Tucker; Epley; Huffman
Date Decided
October 2, 2026
Docket No.
2026-CA-3
Topics
Community control, Revocation, Due process, Sentencing
Source
Read the full opinion

Background

Anthony Quinn Green pleaded guilty in 2015 to fourth-degree-felony domestic violence and received community-control sanctions. After prior violations and extensions of community control, the State filed a third violation notice on December 19, 2025.

The notice alleged that Green had Virginia convictions for assault and battery against a family member and assault on a law-enforcement officer, and that he committed misconduct while being booked and held at the Champaign County Jail. Green moved to dismiss, asserting that his community control had expired and that the timing of the notice based on the Virginia family-member assault conviction violated due process. The trial court denied the motion, found violations, revoked community control, and imposed 14 months in prison.

The Court’s Holding

The Second District affirmed. It held that the December 2025 violation notice was timely because Green’s community control was not scheduled to end until February 2026.

The court also rejected Green’s due-process claim. Even assuming the delay in filing the notice concerning the Virginia conviction was unreasonable, Green did not establish prejudice because the violation rested on the conviction itself rather than underlying conduct. Other violations independently supported revocation. The 14-month term was lawful because it fell within the six-to-18-month range for a fourth-degree felony and the trial court considered Ohio’s felony-sentencing principles and factors.

Key Takeaways

  • A community-control violation notice filed before the supervision term expires is timely.
  • A claimed delay in commencing revocation proceedings requires a showing of prejudice.
  • An appellate court will not reweigh sentencing factors when the sentence is within range and not contrary to law.

Why It Matters

The decision underscores that a delayed violation notice does not warrant dismissal without concrete prejudice. It also confirms the broad sentencing latitude trial courts retain after a community-control violation, subject to statutory sentencing ranges and consideration of the governing felony-sentencing provisions.

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