Conviction for Escape Does Not Require State to Show Postrelease Was Orally Announced at Sentencing

The Supreme Court of Ohio today ruled that, to obtain a conviction for the crime of escape for violating the terms of a post-release control order, the state may prove that a defendant was subject to postrelease control without proving that during a sentencing hearing the trial court orally notified the defendant that he would be subject to postrelease control. The Court’s 5-2 decision was written by Chief Justice Thomas J. Moyer.