State v. Barkley, 2013 Ohio 1545

Barkley appeals sentences from three Cuyahoga County cases (CR-554504, CR-555009, CR-558789) involving grand theft, unauthorized use of a motor vehicle, and forgery/other charges.
In Jan 2012 Barkley withdrew not guilty pleas; pleaded guilty to grand theft (fourth degree) and unauthorized use (fifth degree); remaining charges dismissed or nolle prosequi.
April 2012 Barkley pled guilty to forgery (fifth degree) in the third case; two counts resolved; serial cases remained pending.
May 2012 sentencing hearing: court highlighted Barkley’s extensive prior criminal history and sentenced the three cases to consecutive terms totaling 37 months in prison, plus postrelease control and restitution.
Court ordered each sentence to run consecutively; Barkley informed of three-year postrelease control and $1,197 restitution.
Barkley appealed, contending the court failed to make statutorily required findings to support consecutive sentences under R.C. 2929.14(C)(4); the appeal was sustained and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were properly supported by required findings	Barkley argues the court failed to make the not-disproportionate finding.	State contends sufficient findings were implied by court discussion; not all explicit findings were articulated.	Remanded for explicit findings; order reversed.

State v. Edmonson, 86 Ohio St.3d 324 (Ohio 1999) (requires explicit findings for consecutive sentences)
State v. Johnson, 2012-Ohio-2508 (8th Dist. 2012) (meaningful review of consecutive sentences; statutory findings required)
State v. Jones, 2013-Ohio-489 (8th Dist. 2013) (remand when lack of statutory findings is shown)