State v. Bailey, 2014 Ohio 5720

Bailey was convicted after a plea to felonious assault, tampering with evidence, and a firearm specification stemming from a bar-related armed shooting in Mingo Junction.
Bailey, Hartman, and Hanlin initially confronted victims Willis and Meeks with threats, then Bailey fired seven shots at Willis, causing paralysis.
The group fled, hid the car and two loaded guns, and were later arrested.
Bailey, Hartman, and Hanlin were indicted on multiple counts including attempted murder, felonious assault, tampering with evidence, and firearm specifications.
Bailey pled guilty to remaining charges; Hartman and Hanlin faced related charges in separate indictments; the trial court sentenced all three defendants to consecutive terms totaling 13½ years for Bailey.
The appeal challenges the sentencing methodology, particularly the findings required for consecutive sentences under R.C. 2929.14(C)(4) and the weighing of 2929.11 and 2929.12 factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive-sentence findings complied with R.C. 2929.14(C)(4)	Bailey argues the court failed to make the required findings at sentencing.	Bailey contends the hearings and entry did not satisfy the three statutory findings.	Findings satisfied at hearing and in entry; consecutive sentences upheld.
Whether the court properly applied 2929.11 and 2929.12 factors in sentencing	Bailey claims the court did not adequately address seriousness/recidivism factors.	Bailey asserts insufficient consideration of factors and lack of explicit balancing.	Court's statements and entry demonstrated consideration of 2929.11 and 2929.12; no abuse of discretion.
Whether the sentencing court’s rationale shows the injury to the victim and public safety justified consecutiveness	Bailey argues the harm was overstated or not sufficiently tied to the consecutive-term rationale.	Bailey contends the court did not sufficiently tie harm to necessity of consecutive terms.	Record supports that harm was grave and consequent necessity for consecutive sentences.

State v. Kalish, 120 Ohio St.3d 23 (2008-Ohio-4912) (two-step abuse-of-discretion review for felony sentences; requires consideration of R.C. 2929.11 and 2929.12)
State v. Bonnell, 140 Ohio St.3d 209 (2014-Ohio-3177) (requires findings at sentencing hearing for consecutive sentences; clerical_entry corrections allowed but not substitute)
State v. Hill, 7th Dist. No. 13 CA 82 (2014-Ohio-1965) (sufficiency of record to reveal proper analysis for consecutive-sentence findings)
State v. Power, 7th Dist. No. 12 CO 14 (2013-Ohio-4254) (recognizes need for clear record of consecutive-sentence findings)
State v. McGowan, 2010-Ohio-1309 (7th Dist. No. 09 JE 24) (explains that trial court explanations need not be verbatim statute but must reflect consideration)