State v. Bliffin

2025 Ohio 2809
CourtOhio Court of Appeals
DecidedAugust 11, 2025
Docket2025-A-0001, 2025-A-0002
StatusPublished
Cited by1 cases

This text of 2025 Ohio 2809 (State v. Bliffin) 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. Bliffin, 2025 Ohio 2809 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Bliffin, 2025-Ohio-2809.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT ASHTABULA COUNTY

STATE OF OHIO, CASE NOS. 2025-A-0001 2025-A-0002 Plaintiff-Appellee, Criminal Appeals from the - vs - Court of Common Pleas

DAVID MATTHEW BLIFFIN, Trial Court Nos. 2024 CR 00314 Defendant-Appellant. 2024 CR 00343

OPINION AND JUDGMENT ENTRY

Decided: August 11, 2025 Judgment: Affirmed

April R. Grabman, Ashtabula County Prosecutor, Dane R. Hixon, Assistant Prosecutor, 25 West Jefferson Street, Jefferson, OH 44047 (For Plaintiff-Appellee).

Eric D. Hall, P.O. Box 232, Medina, OH 44258 (For Defendant-Appellant).

EUGENE A. LUCCI, J.

{¶1} Appellant, David Matthew Bliffin, appeals the judgments imposing prison

following his admission to violating probation in two separate cases. We affirm.

{¶2} In 2024, in the trial court case number 2024 CR 00314, Bliffin was charged

with breaking and entering, a fifth-degree felony, in violation of R.C. 2911.13(A) and (C);

and vandalism, a fifth-degree felony, in violation of R.C. 2909.05(B)(1)(b) and (E). In a

separate case, 2024 CR 00343, Bliffin was charged with attempted grand theft of a motor

vehicle, a fifth-degree felony, in violation of R.C. 2923.02 and 2913.02(A)(1) and (B)(5).

{¶3} Following plea negotiations, Bliffin pleaded guilty to the breaking and

entering charge in case number 2024 CR 00314, and the State agreed to dismiss the vandalism charge in that case. In case number 2024 CR 00343, Bliffin pleaded guilty to

an amended count of vandalism, a fifth-degree felony, in violation of R.C.

2909.05(B)(1)(b) and (E). The trial court sentenced Bliffin to concurrent, two-year terms

of community control in each case. As part of the community control conditions, the trial

court required Bliffin to enter, and successfully complete, residential treatment at Alpha

House and follow any aftercare recommendations.

{¶4} Thereafter, the probation department filed complaints in each case alleging

that Bliffin violated the terms of his community control due to his unsuccessful discharge

from Alpha House. Bliffin waived the probable cause hearings and requested the matters

be set for final hearings. Following negotiations with the State, Bliffin admitted the

violations. The parties jointly recommended a 12-month term of incarceration in each

case, to run concurrently, with 134 days of jail credit. The trial court adopted the

recommendation and imposed sentences accordingly.

{¶5} Bliffin noticed appeals from each sentencing entry, and this court

consolidated the appeals for all purposes. In his sole assigned error, Bliffin argues:

{¶6} “The trial court erred when it sentenced appellant to a prison term when

clearly and convincingly the record failed to support its findings.”

{¶7} Bliffin challenges the trial court’s imposition of prison sentences on his

community control violations. “The Ohio Supreme Court has affirmed that a hearing to

impose a sentence for a violation of community control is a sentencing hearing and,

therefore, compliance with the relevant sentencing statutes is required.” State v. Scott,

2021-Ohio-1368, ¶ 13 (11th Dist.), citing State v. Jackson, 2016-Ohio-8127, ¶ 11.

PAGE 2 OF 7

Case Nos. 2025-A-0001 and 2025-A-0002 {¶8} “‘As with all felony sentences, we review the trial court’s sentencing decision

for a community control violation under the standard set forth by R.C. 2953.08(G)(2).’”

State v. Hogya, 2024-Ohio-639, ¶ 11 (11th Dist.), quoting State v. Demangone, 2023-

Ohio-2522, ¶ 11 (12th Dist.); and State v. Elliott, 2023-Ohio-1459, ¶ 11 (1st Dist.).

{¶9} R.C. 2953.08(G)(2) provides:

The court hearing an appeal under division (A), (B), or (C) of this section shall review the record, including the findings underlying the sentence or modification given by the sentencing court.

The appellate court may increase, reduce, or otherwise modify a sentence that is appealed under this section or may vacate the sentence and remand the matter to the sentencing court for resentencing. The appellate court's standard for review is not whether the sentencing court abused its discretion. The appellate court may take any action authorized by this division if it clearly and convincingly finds either of the following:

(a) That the record does not support the sentencing court’s findings under division (B) or (D) of section 2929.13, division (B)(2)(e) or (C)(4) of section 2929.14, or division (I) of section 2929.20 of the Revised Code, whichever, if any, is relevant;

(b) That the sentence is otherwise contrary to law.

{¶10} However, R.C. 2953.08(D)(1) precludes our review of a sentence under that

section “if the sentence is authorized by law, has been recommended jointly by the

defendant and the prosecution in the case, and is imposed by a sentencing judge.” “[T]o

be ‘authorized by law’ under R.C. 2953.08(D)(1), a sentence must comport with all

applicable mandatory sentencing provisions.” (Internal citation omitted.) State v. Sergent,

2016-Ohio-2696, ¶ 29.

PAGE 3 OF 7

Case Nos. 2025-A-0001 and 2025-A-0002 {¶11} Here, as discussed in our recitation of the facts, the parties jointly

recommended the concurrent, 12-month prison term imposed in each case. Thus, R.C.

2953.08(D)(1) precludes our review of these sentences if they are authorized by law.

{¶12} With respect to sentencing on community control violations, R.C.

2929.15(B)(1)(c) provides that, subject to certain conditions, a trial court may impose a

prison term on an offender who violates community control. The prison term may not

exceed the term specific in the notice provided to the offender at the sentencing hearing

on the underlying offense. R.C. 2929.15(B)(3). In addition, “[i]f the prison term is imposed

for any technical violation of the conditions of a community control sanction imposed for

a felony of the fifth degree, the prison term shall not exceed ninety days.” R.C.

2929.15(B)(1)(c)(i).

{¶13} In 2021, the legislature amended R.C. 2929.15 to include a definition of a

“technical violation” as follows:

As used in this section, “technical violation” means a violation of the conditions of a community control sanction imposed for a felony of the fifth degree. . . and to which neither of the following applies:

(1) The violation consists of a new criminal offense that is a felony or that is a misdemeanor other than a minor misdemeanor, and the violation is committed while under the community control sanction.

(2) The violation consists of or includes the offender’s articulated or demonstrated refusal to participate in the community control sanction imposed on the offender or any of its conditions, and the refusal demonstrates to the court that the offender has abandoned the objects of the community control sanction or condition.

R.C. 2929.15(E). See State v. Duckett, 2021-Ohio-3110, ¶ 17 (4th Dist.), quoting State v.

Davis, 2018-Ohio-2672, ¶ 17 (12th Dist.) (discussing the prior judicially created definition PAGE 4 OF 7

Case Nos. 2025-A-0001 and 2025-A-0002 of a “technical violation” as being “akin to ‘an administrative requirement facilitating

community control supervision’”).

{¶14} Accordingly, R.C. 2953.08(D)(1) precludes our review of the 12-month

sentences imposed for the community control violations unless: (1) the sentences exceed

the terms specified in the notices provided to Bliffin at the original sentencing hearings,

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Bluebook (online)
2025 Ohio 2809, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bliffin-ohioctapp-2025.