State v. Burroughs

2026 Ohio 166
CourtOhio Court of Appeals
DecidedJanuary 20, 2026
Docket3-25-23, 3-25-24
StatusPublished

This text of 2026 Ohio 166 (State v. Burroughs) 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. Burroughs, 2026 Ohio 166 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Burroughs, 2026-Ohio-166.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT CRAWFORD COUNTY

STATE OF OHIO, CASE NO. 3-25-23 PLAINTIFF-APPELLEE,

v.

STEFANIE BURROUGHS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

STATE OF OHIO, CASE NO. 3-25-34 PLAINTIFF-APPELLEE,

STEFANIE BURROUGHS, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLANT.

Appeals from Crawford County Common Pleas Court Trial Court Nos. 23-CR-0020 and 23-CR-0205

Judgments Affirmed

Date of Decision: January 20, 2026 Case Nos. 3-25-23, 3-25-24

APPEARANCES:

William T. Cramer for Appellant

Daniel J. Stanley for Appellee

WALDICK, J.

{¶1} This is a consolidated appeal in which the defendant-appellant, Stefanie

Burroughs (“Burroughs”), appeals the July 28, 2025 judgments of the Crawford

County Court of Common Pleas in two cases in which the trial court revoked

Burroughs’ community control and imposed a 7-month term of incarceration. For

the reasons set forth below, we affirm.

Procedural History

{¶2} In Case Number 3-35-23 (23-CR-020), an indictment was returned

against Burroughs on January 24, 2023. In the sole count of that indictment,

Burroughs was charged with Violating a Protection Order, a fifth-degree felony in

violation of R.C. 2919.27(A)(1) and (B)(3)(a). On May 1, 2023, Burroughs pled

guilty to the charge in the indictment, and was sentenced to a five-year term of

community control.

{¶3} In Case Number 3-25-24 (23-CR-205), an indictment was returned

against Burroughs on July 11, 2023. That single-count indictment charged

-2- Case Nos. 3-25-23, 3-25-24

Burroughs with Violating a Protection Order, a fifth-degree felony in violation of

R.C. 2919.27(A)(2) and (B)(3)(c). On July 3, 2024, Burroughs pled guilty to the

charge in that indictment, and was sentenced to a five-year term of community

control.

{¶4} As a result of Burroughs being charged with a felony in the second case,

a community control violation was filed against Burroughs in the earlier case. On

July 3, 2024, when the second case was resolved with Burroughs’ guilty plea, she

also admitted the community control violation in the earlier case. At that time, the

trial court ordered that Burroughs be continued on community control in the first

case.

{¶5} On March 17, 2025, a notice of an alleged community control violation

was filed in both cases. Those notices alleged that Burroughs had violated the terms

of her community control on March 13, 2025 in two ways: (1) that Burroughs had

committed Domestic Violence and Assault, and (2) that Burroughs had consumed

alcohol.

{¶6} On July 2, 2025, an evidentiary hearing was held on the alleged

community control violations. At the hearing, the State of Ohio presented the

testimony of Crawford County Probation Officer Jeremy Clay, along with two

evidentiary exhibits. After the state rested its case, the defense presented the

testimony of Burroughs and her boyfriend, Jonathan Barrier, along with one

evidentiary exhibit consisting of 14 photographs. Following the presentation of

-3- Case Nos. 3-25-23, 3-25-24

evidence, the trial court ruled from the bench and found that Burroughs had violated

the terms of community control as alleged in both cases. On July 3, 2025, the trial

court filed a judgment entry in both cases reflecting the court’s findings that the

terms of Burroughs’ community control had been violated.

{¶7} On July 23, 2025, a dispositional hearing was held in both cases with

regard to the community control violations. At that time, the trial court terminated

the community control as unsuccessful in both cases, and sentenced Burroughs to a

prison term of seven months in each case, to be served concurrently. The trial court

further ordered that the prison terms be served in the Crawford County Jail.

{¶8} On July 28, 2025, the trial court journalized its sentencing decisions in

the two cases. On August 1, 2025, the trial court filed a nunc pro tunc judgment

entry in both cases, correcting a typographical error in the July 28, 2025 judgment

entries.

{¶9} On August 13, 2025, Burroughs filed a notice of appeal in each

case. This court subsequently ordered that the two appeals be consolidated.

{¶10} On appeal, Burroughs raises three assignments of error for our review.

First Assignment of Error

The weight of the evidence does not support the trial court’s finding that appellant violated the law by committing the crimes of assault and domestic violence.

-4- Case Nos. 3-25-23, 3-25-24

Second Assignment of Error

The trial court abused its discretion by terminating community control and imposing a lengthy jail sentence.

Third Assignment of Error

The trial court erred by imposing more than 90 days for the technical violation of consuming alcohol.

Analysis of Assignments of Error

{¶11} In the first assignment of error, Burroughs asserts that the trial court’s

finding that she violated her community control was against the manifest weight of

the evidence with regard to the first of the two alleged community control violations.

{¶12} In the two cases involved in this appeal, the notices of community

control violations filed on March 17, 2025 alleged that Burroughs had violated the

terms of her community control in two ways. Specifically, the notices alleged that

(1) on March 13, 2025, Burroughs had committed Domestic Violence and Assault,

a violation of Community Control Condition #1, pursuant to which Burroughs was

required to obey all federal, state, and local laws and conduct herself as a responsible

law-abiding citizen; and (2) on March 13, 2025, Burroughs had consumed alcohol,

a violation of Community Control Condition #13, pursuant to which Burroughs was

prohibited from purchasing, possessing, or consuming any alcoholic beverage.

-5- Case Nos. 3-25-23, 3-25-24

{¶13} In this assignment of error, Burroughs argues that the trial court lost

its way in finding that Burroughs had violated Community Control Condition #1, a

violation based on the allegation that Burroughs had assaulted her sister.

{¶14} A trial court’s finding of a community control violation will not be

disturbed absent an abuse of discretion. State v. Sandlin, 2022-Ohio-570, ¶ 15 (3d

Dist.). An abuse of discretion suggests that a decision is unreasonable, arbitrary, or

unconscionable. State v. Adams, 62 Ohio St.2d 151, 157-158 (1980).

As this Court explained in State v. Wallace, 2023-Ohio-676 (3d Dist.):

“Because a community control violation hearing is not a criminal trial, the State need not prove a violation beyond a reasonable doubt.” State v. Roberts, 2d Dist. Champaign No. 2016-CA-8, 2017-Ohio- 481, ¶ 20, 84 N.E.3d 339. Rather, “the State must show substantial evidence that the offender violated the terms of his community- control sanctions at a community-control-revocation hearing.” State v. Boykins, 3d Dist. Marion No. 9-14-28, 2015-Ohio-1341, ¶ 20. ‘Substantial evidence is akin to a preponderance-of-the-evidence burden of proof.’ State v. Burdette, 5th Dist. Morrow No. 10-CA-9, 2011-Ohio-4425, * * *. ‘Substantial evidence is considered to consist of more than a mere scintilla of evidence, but somewhat less than a preponderance.’ Id. * * *. (Citations omitted.) Id. at ¶ 21.

Id., at ¶ 12.

{¶15} Community control revocation hearings are not subject to the rules of

evidence and hearsay evidence is admissible.

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State v. Sullivan
2017 Ohio 8937 (Ohio Court of Appeals, 2017)
State v. Sandlin
2022 Ohio 570 (Ohio Court of Appeals, 2022)
State v. Blankenship
2022 Ohio 1808 (Ohio Court of Appeals, 2022)
State v. Adams
404 N.E.2d 144 (Ohio Supreme Court, 1980)
State v. Mullins
2022 Ohio 4686 (Ohio Court of Appeals, 2022)
State v. Runion
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State v. Brill
2023 Ohio 404 (Ohio Court of Appeals, 2023)
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2023 Ohio 676 (Ohio Court of Appeals, 2023)
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2026 Ohio 166, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-burroughs-ohioctapp-2026.