State v. Barone

2025 Ohio 1695
CourtOhio Court of Appeals
DecidedMay 12, 2025
DocketCA2024-09-061
StatusPublished
Cited by1 cases

This text of 2025 Ohio 1695 (State v. Barone) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Barone, 2025 Ohio 1695 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Barone, 2025-Ohio-1695.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

WARREN COUNTY

STATE OF OHIO, :

Appellee, : CASE NO. CA2024-09-961

: O P I N I O N AND - vs - JUDGMENT ENTRY : 5/12/2025

GERALD MICHAEL BARONE, :

Appellant. :

CRIMINAL APPEAL FROM WARREN COUNTY COURT Case No. 2021TRC001900

David P. Fornshell, Warren County Prosecuting Attorney, and Kirsten A. Brandt, Assistant Prosecuting Attorney, for appellee.

Jeffrey C. Meadows, for appellant.

___________ OPINION

HENDRICKSON, P.J.

{¶ 1} Gerald Michael Barone appeals the judgment of the Warren County Court

finding that he violated his probation. For the reasons set forth below, we affirm the trial

court's judgment.

I. Facts and Procedural Background

{¶ 2} In November 2021, Barone was charged with two counts of operating a Warren CA2024-09-061

vehicle while under the influence of alcohol ("OVI") and one count of driving in marked

lanes. On April 26, 2022, Barone pleaded guilty to one count of OVI, and the remaining

charges were dismissed. The trial court sentenced Barone to 180 days in jail with 170

days suspended, suspended his driver's license for two years, and imposed a two-year

period of basic probation—until April 26, 2024.

{¶ 3} On January 19, 2023, about nine months into his probation, Barone met

with his probation officer who gave him a document that indicated his probation would

terminate on April 26, 2023. The document stated: "PROBATION ENDS 04/26/23. CALL

IF ANY CHANGES." This termination date was erroneous: it was one year earlier than

the two-year probation period originally imposed by the trial court.

{¶ 4} On April 5, 2024—approximately one year after the erroneous termination

date but before the actual expiration of the two-year probation period—Barone was

charged in municipal court with new offenses of OVI and refusal to submit to a chemical

test. He was subsequently convicted of OVI. On April 15, 2024, Barone's probation officer

filed a probation-violation report alleging that Barone had violated conditions of his

probation by (1) committing new criminal offenses, (2) failing to notify his probation officer

of the new charges, and (3) failing to submit to a breathalyzer test.

{¶ 5} On May 28, 2024, Barone filed a motion to terminate his probation,

asserting that he had relied in good faith on the document provided by his probation officer

indicating that his probation terminated on April 26, 2023. At the final probation violation

hearing on August 15, 2024, Barone pleaded no contest to violating the condition of

probation requiring him to refrain from committing criminal offenses. Barone

acknowledged that the original sentencing entry set forth a two-year period of probation

and that, technically, he was still on probation when he committed the new offenses. But

Barone argued that he had a good faith belief that his probation had ended based on the

-2- Warren CA2024-09-061

document from his probation officer and that the document created a "de facto

termination" of his probation.

{¶ 6} The trial court found Barone guilty of violating his probation by committing

a new criminal offense. The court recognized the probation officer's error but determined

that it would only mitigate the violations for failing to inform the probation officer of the

new charges and failing to submit to a breathalyzer test—not for committing a new

criminal offense. The court sentenced Barone to 20 days in jail with work release and

ordered that his probation terminate upon completion of the jail term. The court stayed

execution of the jail term pending appeal.

II. Analysis

{¶ 7} Barone presents a single assignment of error:

THE TRIAL COURT ERRED IN FINDING THAT DEFENDANT VIOLATED PROBATION/COMMUNITY CONTROL.

{¶ 8} A trial court's decision finding a defendant in violation of community control

will not be disturbed on appeal absent an abuse of discretion. State v. Kincer, 2006-Ohio-

2249, ¶ 5 (12th Dist.). An abuse of discretion implies more than an error of law or

judgment; it suggests that the trial court's attitude was unreasonable, arbitrary, or

unconscionable. Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983). Under this

deferential standard, an appellate court may not substitute its judgment for that of the trial

court. State v. Edwards, 2023-Ohio-2632, ¶ 34 (12th Dist.).

{¶ 9} Barone argues that because he was given notice of termination of his

probation by the probation department itself, there was a "de facto termination" in April

2023, and the rules of probation no longer applied to him after that date. Barone contends

that the trial court abused its discretion by finding him guilty of violating probation for

conduct that occurred after he had been informed by the probation department that his

-3- Warren CA2024-09-061

probation had terminated. Barone further argues that principles of fundamental fairness

dictate that the trial court's decision should be reversed.

{¶ 10} In response, the State argues that the trial court did not abuse its discretion

in finding that Barone violated his probation by committing new offenses. The State

emphasizes that the court's original sentencing entry ordered a two-year term of

probation, and Barone did not receive any official court document, signed by a judge,

terminating his probation early. The State contends that, absent such an official entry,

Barone remained subject to the conditions of probation until April 26, 2024, including the

requirement that he not commit additional offenses.

{¶ 11} When imposing community-control sanctions, like probation, for a

misdemeanor offense, a sentencing court retains jurisdiction over the offender for the

duration of the period of community control. R.C. 2929.25(B). A requirement that the

offender "abide by the law" is a mandatory condition of any community-control sanction.

R.C. 2929.25(C)(2). If a defendant violates a condition of community control, the

sentencing court may impose upon the violator one or more penalties, including a jail

term. R.C. 2929.25(D)(2).

{¶ 12} The Ohio Supreme Court has held that a trial court "loses jurisdiction" to

impose a sentence if "the state fails to initiate probation violation proceedings during the

original probation period." State v. Yates, 58 Ohio St.3d 78, 80 (1991). Similarly, the Sixth

District Court of Appeals has stated that "when the State fails to initiate community control

violation proceedings during the original term of community control, the trial court loses

its jurisdiction to extend that sanction." State v. Fairbank, 2006-Ohio-6180, ¶ 11 (6th

Dist.). But these jurisdictional limitations are predicated on the expiration of the originally

imposed term of community control. The question presented in this case is whether an

erroneous notice from a probation officer can effectively terminate probation before the

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expiration of the court-ordered term.

{¶ 13} Barone's reference to the concept of "de facto termination" finds no support

in Ohio law. The cases cited by Barone regarding a court's loss of jurisdiction refer to

situations where the state fails to initiate violation proceedings during the original

probation period.

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State v. Barone
2025 Ohio 1695 (Ohio Court of Appeals, 2025)

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