Beachwood v. Chatmon, 2015 Ohio 425

Glen Chatmon pleaded no contest to two counts of misdemeanor theft in Shaker Heights Municipal Court.
Sentencing occurred July 14, 2014; Chatmon was not represented by counsel at that hearing and there is no record of counsel appearing.
The court imposed on each count a $600 fine (with $300 suspended), six months jail, and five years inactive probation; the jail terms were ordered to run consecutively for a total of one year.
The court made no on-the-record R.C. 2929.14(C)(4) findings at sentencing; the journal entry stated only that consecutive sentences were imposed "due to continuing criminal activity."
The City conceded the trial court failed to make the statutory findings required for consecutive sentences.
The court of appeals reversed, vacated the sentences, and remanded for resentencing requiring on-the-record findings and journalization per applicable precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court lawfully imposed consecutive misdemeanor sentences without making R.C. 2929.14(C)(4) findings	Consecutive sentences were justified (City conceded procedural omission)	Consecutive sentences invalid because statutory findings were not made on the record and in the entry	Reversed and vacated: consecutive sentences invalid; remand for resentencing with required findings
Whether sentencing without counsel present was reversible error	Not argued in detail; City did not contest the dispositive statutory-finding error	Chatmon argued sentencing occurred without his counsel present, violating his rights	Deemed moot by disposition on statutory-finding error; trial court’s lack of counsel appearance noted but not decided on merits

State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings both on the record and in the sentencing entry before imposing consecutive sentences)