State v. Rankin

2025 Ohio 4395
CourtOhio Court of Appeals
DecidedSeptember 19, 2025
Docket30330
StatusPublished

This text of 2025 Ohio 4395 (State v. Rankin) 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. Rankin, 2025 Ohio 4395 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Rankin, 2025-Ohio-4395.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

STATE OF OHIO : : C.A. No. 30330 Appellee : : Trial Court Case No. 2020 CR 03284 v. : : (Criminal Appeal from Common Pleas JACQUELINE R. RANKIN : Court) : Appellant : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on September 19, 2025, the judgment

of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

EPLEY, P.J., and HANSEMAN, J., concur. -2- OPINION MONTGOMERY C.A. No. 30330

MARY ADELINE R. LEWIS, Attorney for Appellant SARAH H. CHANEY, Attorney for Appellee

TUCKER, J.

{¶ 1} Jacqueline R. Rankin appeals from the trial court’s revocation of community

control and imposition of an 18-month prison sentence for felony child endangering.

{¶ 2} Rankin contends that following her admission to violating community control by

absconding, the trial court infringed on her due process rights by revoking community control

without requiring the State to present evidence of the other violations alleged in her notice

of community control revocation.

{¶ 3} We conclude that the trial court was not required to consider the other alleged

violations after Rankin admitted one violation. The trial court also did not rely on the other

alleged violations when revoking community control and imposing a prison sentence.

Finding no due process violation, we affirm the trial court’s judgment.

I. Background

{¶ 4} In November 2020, a grand jury indicted Rankin on two counts of felony child

endangering. She later pled guilty to one count in exchange for dismissal of the other. The

trial court accepted the plea and made a finding of guilt. On March 3, 2022, the trial court

sentenced Rankin to community control sanctions. The terms of her community control

included completing a residential treatment program. On March 24, 2022, the trial court

declared Rankin an absconder, noting that her whereabouts were unknown, and issued a

capias for her arrest. More than two years later, she was found and arrested. -3- {¶ 5} On December 13, 2024, a notice of community control revocation was filed

alleging violations of rule numbers one, three, four, and five of the terms of her community

control sanctions. A hearing on the notice followed on December 18, 2024, where Rankin

waived a probable cause hearing and admitted to violating rule number five by absconding.

See Tr. 9. The trial court accepted the admission and proceeded to revocation and

sentencing without addressing the other three alleged violations. The trial court

characterized Rankin’s child endangering offense as “pretty egregious” and observed that

she “really hasn’t done anything as it pertains to—to court.” It revoked community control

and imposed an 18-month prison sentence. Tr. 10-12. This appeal followed.

II. Analysis

{¶ 6} Rankin’s assignment of error states:

The Appellant’s due process rights were violated when the Court

failed to require the State to present evidence supporting violations of

rules one, two, three, and four as the only admission by the Appellant

was to a rule five violation.

{¶ 7} Although Rankin admitted to violating community control rule number five, she

points out that her other alleged violations were not addressed by the trial court. She asserts

that the trial court violated due process by considering these other alleged violations when

deciding to revoke community control and impose a prison term.1

{¶ 8} In support of her argument, Rankin notes that rule number five provided: “I shall

report at such time and place as directed by my Probation Officer. If my Probation Officer is

unavailable, I shall report to the Officer-of-the-Day, the Supervisor, the Manager, or

1 In her assignment of error, Rankin contends she was accused of violating five community-

control rules. The record reflects, however, that she allegedly violated four rules. -4- Director.” Rankin stresses that other community control conditions required her to do more

than simply “report” to her supervisor. She then cites the trial court’s observation that she

really had not “done anything as it pertains . . . to court.” Rankin infers from this statement

about her not doing “anything” that the trial court relied on the other alleged violations when

deciding to revoke community control.

{¶ 9} In response, the State maintains that the other alleged violations were

“effectively dismissed” after Rankin admitted violating rule five by absconding. If the other

alleged violations had remained pending, the State reasons that the court’s sentencing entry

would not have been a final, appealable order. The State also argues that the trial court did

not rely on the other alleged violations when deciding to revoke community control.

Alternatively, the State insists that the trial court was entitled to consider the unaddressed

alleged violations for purposes of sentencing.

{¶ 10} Upon review, we note that Rankin likely waived all but plain error by failing to

object to the alleged due process violation during the hearing below. State v. Klosterman,

2016-Ohio-232, ¶ 15 (2d Dist.) (“The failure to object to a due process violation during a

community control revocation hearing waives all but plain error.”). We need not dwell on that

issue, however, as we find no error in the revocation proceeding, plain or otherwise.

{¶ 11} The notice of community control revocation alleged that Rankin had violated

rule one by being charged with misdemeanors in Dayton Municipal Court; had violated rule

three by changing her address without notice; had violated rule four by failing to obtain,

maintain, and verify employment; and had violated rule five by absconding, leaving the

residential treatment program, and failing to report to the probation department.

{¶ 12} As noted above, Rankin admitted to violating the fifth rule. The record

establishes that she spent only about five days at the residential facility before leaving -5- without permission and disappearing for well over two-and-a-half years. Against this

backdrop, the trial court’s statement that she had not “done anything” pertaining to court

since being placed on community control seems to have been related to her status as an

absconder, not to the other alleged violations. By absconding, Rankin in fact had not done

anything for the court for almost three years. The trial court’s remarks do not suggest that it

relied on new misdemeanor charges, the lack of notice of an address change, or a lack of

employment when it revoked community control and imposed a prison term. In light of this

conclusion, we need not address the State’s alternative argument about the trial court being

entitled to consider the other alleged violations for purposes of sentencing.

{¶ 13} We also need not decide whether the other alleged violations were “effectively

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Related

State v. Klosterman
2016 Ohio 232 (Ohio Court of Appeals, 2016)
State v. Craig (Slip Opinion)
2020 Ohio 455 (Ohio Supreme Court, 2020)
State v. Hutchinson
2020 UT App 10 (Court of Appeals of Utah, 2020)

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2025 Ohio 4395, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-rankin-ohioctapp-2025.