State v. Alexander, 2017 Ohio 4196

Appellant Leon M. Alexander pleaded guilty to: aggravated burglary (1st deg.) with a Repeat Violent Offender (RVO) specification, attempted kidnapping with a sexual-motivation specification (2nd deg.), possessing criminal tools (5th deg.), aggravated robbery (1st deg.), and felonious assault (2nd deg.).
The trial court accepted the plea, nolled an attempted-rape count and other specifications, and ordered a PSI prior to sentencing.
Victim testimony at sentencing described a violent home invasion of an 89-year-old woman causing serious physical and psychological injury.
The court imposed the maximum 11-year term on aggravated burglary, then exercised discretion to add an RVO term (10 years) to be served consecutively, and ran remaining counts concurrently, producing a 21-year aggregate sentence.
Appellant did not object to consecutive sentencing at the hearing and appealed, arguing the consecutive terms violated Ohio sentencing statutes and due process.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Alexander)	Held
Whether consecutive sentences (aggravated burglary + RVO term) were improper	Consecutive RVO term is mandatory when the underlying violent offense receives the maximum term and the court elects to impose the additional term under R.C. 2929.14(B)(2)	Consecutive terms violate R.C. 2929.14, R.C. 2929.11(B) and 2929.11(A); trial court failed to consider proportionality, mitigating factors, and less restrictive sanctions	Affirmed: consecutive sentencing was mandatory under the RVO statute; no plain error shown

State v. Sergent, 148 Ohio St.3d 94 (2016) (explains when consecutive sentences are mandatory vs. discretionary and how R.C. 2929.14 interacts with consecutive terms)
State v. Bonnell, 140 Ohio St.3d 209 (2014) (requires consecutive-sentence findings at sentencing when judge exercises discretion under R.C. 2929.14(C)(4))
State v. Payne, 114 Ohio St.3d 502 (2007) (places burden of demonstrating plain error on the party asserting it)