State v. Alexander, 2016 Ohio 204

Defendant Antonio Alexander pleaded guilty (2013) to two misdemeanors relevant here: child endangerment and disseminating matter harmful to a juvenile; placed on community control.
After violating community control, the trial court imposed six-month jail terms on each misdemeanor count, ordered to run consecutively, credited 34 days of time served, producing a one-year aggregate jail sentence (other counts concurrent).
Alexander appealed solely arguing the trial court failed to make the R.C. 2929.14(C)(4) findings required for consecutive sentences.
The court analyzed whether R.C. 2929.14(C)(4) (governing consecutive prison terms) applies to consecutive misdemeanor jail terms.
The court concluded R.C. 2929.41(B) permits consecutive misdemeanor jail terms (aggregate cap 18 months) without the R.C. 2929.14(C)(4) findings and affirmed the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2929.14(C)(4) findings were required before imposing consecutive misdemeanor jail terms	State: sentencing did not require the R.C. 2929.14(C)(4) findings because misdemeanors are governed by R.C. 2929.41(B)	Alexander: trial court must make R.C. 2929.14(C)(4) consecutive-sentence findings before imposing consecutive jail terms	Held: R.C. 2929.14(C)(4) applies only to prison terms; R.C. 2929.41(B) authorizes consecutive misdemeanor jail terms up to 18 months without those findings; conviction affirmed

None of the state appellate decisions cited in the opinion have official reporter citations supplied in the opinion (the court relied on prior Ohio appellate decisions interpreting R.C. 2929.41(B) and distinguishing R.C. 2929.14(C)(4)).