State v. Anderson, 2020 Ohio 4083

Anderson was indicted on multiple counts arising from July–August 2019 incidents involving his ex‑girlfriend A.P.; he pled guilty to two counts of violating a protection order (third‑degree felonies) as part of a plea agreement dismissing other charges.
The plea agreement included a presentence investigation (PSI).
Anderson attempted to withdraw his guilty plea, presenting a notarized recantation letter from A.P.; at hearing A.P. testified the letter was false and that Anderson had coerced her to sign it. The trial court denied withdrawal.
At sentencing the court imposed 2 years on one count and the maximum 3 years on the other, ordered consecutively for an aggregate five‑year prison term.
Anderson appealed, challenging (1) the record support for consecutive sentences, (2) the record support for the aggregate five‑year term, and (3) whether the sentence was otherwise contrary to law.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Anderson)	Held
Whether trial court’s consecutive‑sentence findings were supported by the record under R.C. 2929.14(C)(4)	Record (PSI, criminal history, post‑offense contacts, lack of remorse) supports findings that consecutive terms are necessary and not disproportionate	Record does not support consecutive terms; findings unsupported	Affirmed: findings were made at hearing and incorporated in journal; record does not clearly and convincingly fail to support them
Whether the imposition of the maximum 3‑year term (and aggregate 5 years) was contrary to law	Sentence within statutory range; court considered R.C. 2929.11/2929.12 in entry; exercise of discretion	Maximum and consecutive aggregate term unjustified; community control should have been considered	Affirmed: sentence within statutory range and court stated it considered sentencing statutes; not clearly and convincingly contrary to law
Whether the overall sentence was unsupported by the record (Marcum standard)	PSI and record showed pattern of domestic violence, multiple protection‑order violations, and disregard for orders — supporting imprisonment	Record insufficient to show necessity of maximum/consecutive confinement	Affirmed: under deferential review, record contains substantial factual support for sentence

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (sets R.C. 2953.08(G)(2) standard for appellate review of felony sentences)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make required consecutive‑sentence findings and incorporate them in the judgment entry)
State v. Wiles, 571 N.E.2d 97 (Ohio 1991) (trial court may consider facts supporting a charge even if jury acquitted)
State v. Withrow, 64 N.E.3d 553 (Ohio App. 2016) (explains deferential standard: appellate court must clearly and convincingly find record failed to support consecutive findings)