State v. Delaney

The Ohio Supreme Court noted, in State v. Delaney (1984), 11 Ohio St.3d 231, 11 Ohio B. 545, 465 N.E.2d 72, that oral explanations of the violation may satisfy this requirement. The Court found that: Although we do not condone the use of oral "explanations" in lieu of written statements detailing the basis for a trial court's determination in revocation proceedings, we find that, in this case, the trial court's statement sufficiently informed the appellant of the reasons for which his probation was being revoked, while also providing an adequate record for review on appeal. State v. Delaney, 11 Ohio St.3d at 235.