State v. Akins-Daniels, 2016 Ohio 7048

Defendant Anthony Akins-Daniels and an accomplice burglarized a home; the armed homeowner returned, shot both intruders; the accomplice died and Akins-Daniels fled wounded.
Akins-Daniels pleaded guilty to involuntary manslaughter (R.C. 2903.04(A)), aggravated burglary (R.C. 2911.11(A)(2)), and related firearm specifications; plea reduced original murder charge exposure.
At sentencing the trial court imposed an 11-year term for involuntary manslaughter + a consecutive 3-year firearm specification (14 years total); other counts concurrent.
Akins-Daniels appealed, arguing the 11-year manslaughter term (maximum for that offense) was excessive and urging reconsideration of mitigating/weighting of sentencing factors under R.C. 2929.11/2929.12.
The majority panel affirmed, holding (1) R.C. 2953.08 limits appellate reweighing of sentencing factors and (2) the sentence was the product of a jointly recommended plea range (10–25 years) and thus not reviewable under R.C. 2953.08(D)(1).
Judge Celebrezze concurred in the judgment but disagreed that a plea agreeing only to a sentencing floor ("at least 10 years") necessarily bars review of all sentences within a subsequently imposed range.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Akins-Daniels)	Held
Whether the 11-year manslaughter sentence is reviewable as "contrary to law" under R.C. 2953.08	Sentence is permissible and supported by record; appellate review is limited to clear-and-convincing demonstrations that record fails to support trial findings or sentence is contrary to law	Trial court improperly weighted mitigating factors; urges appellate reconsideration to reduce sentence	Denied — defendant failed to show by clear and convincing evidence that the record does not support the sentence; appellate courts may not reweigh factors absent a clear statutory basis to vacate
Whether a jointly recommended plea that specified a sentencing range (10–25 years) renders the imposed within-range sentence unreviewable under R.C. 2953.08(D)(1)	The plea was a joint recommendation (minimum 10 up to 25) so the resulting within-range sentence is not subject to appeal under R.C. 2953.08(D)(1)	Argues he only agreed to a 10-year floor, not every sentence within 10–25 years, so appellate review should be available	Majority: Held not reviewable as joint recommendation authorized by law; concurrence: disagreed that a floor necessarily precludes review but concurred in outcome because assigned errors lacked merit

Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel withdrawing and frivolous appeals)
State v. Underwood, 124 Ohio St.3d 365 (Ohio 2010) (a sentence jointly recommended by defendant and prosecution and imposed by the court is not subject to R.C. 2953.08 review if it comports with mandatory sentencing provisions)
State v. Gilbert, 143 Ohio St.3d 150 (Ohio 2014) (discusses enforcement and waiver consequences of plea agreements)