State v. Barber, 2016 Ohio 1409

Michael R. Barber was convicted after a jury trial of two counts of drug possession (one first-degree felony, one third-degree felony).
On initial appeal, this court affirmed all issues except the imposition of consecutive sentences; the case was remanded for resentencing because the trial court had not made the R.C. 2929.14(C)(4) findings.
On remand, the trial court resentenced Barber to 11 years (Count 1) plus 3 years (Count 2), ordered to run consecutively for a total of 14 years; an amended judgment entry incorporated oral findings.
Appellate counsel filed an Anders brief stating there was no nonfrivolous issue on appeal limited to the resentencing and sought leave to withdraw; Barber filed no supplemental brief.
The court independently reviewed the record, examined whether the statutory consecutive-sentence findings were made and supported by the record, and found no nonfrivolous issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly imposed consecutive sentences under R.C. 2929.14(C)(4)	Trial court made the requisite findings on the record and in the amended judgment entry supporting consecutive sentences	Barber (via Anders brief) implicitly argued no colorable issue; primary challenge was that consecutive-sentence findings were insufficient	Court held the trial court made the required findings (necessity to protect/punish, proportionality, and at least one statutory predicate including unusually grave harm and criminal-history predicate) and affirmed the sentence

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedure when counsel concludes an appeal is frivolous)
Penson v. Ohio, 488 U.S. 75 (U.S. 1988) (appellate court must independently review the record after an Anders brief)
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court need not recite statutory language verbatim but must make discernible consecutive-sentence findings)