State v. Barnes, 2017 Ohio 2599

Joanna A. Barnes pled guilty to one count of felonious assault (R.C. 2903.11(A)(1)) for a November 26, 2015 assault on her mother in which Barnes and her sister attempted to choke their mother with braided USB cords and a towel; the victim suffered severe neck lacerations and bruising and incurred medical bills.
Barnes admitted guilt at plea hearing; case was referred for PSI and psychological evaluation. She had no prior criminal record. Psychological reports showed PTSD, major depressive disorder, borderline personality disorder, prior hospitalizations, and allegations of long-term childhood abuse (largely uncorroborated).
Defense requested community control to allow mental-health treatment; the State recommended seven years in prison.
At sentencing the court considered the PSI, victim impact statement, psychological evaluation, and statements from Barnes and the victim; court found limited evidence of genuine remorse.
The court imposed a seven-year prison term (below the eight-year statutory maximum) and entered judgment on August 25, 2016. Barnes appealed, arguing the court failed to consider mitigating factors under R.C. 2929.12.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence is contrary to law because the trial court failed to consider mitigating factors under R.C. 2929.12	State: trial court considered statutory factors and balanced seriousness/recidivism; sentence supported by record	Barnes: court ignored mitigating factors (mental illness, history of abuse, remorse) under R.C. 2929.12(C)(4) and (E)(5)	Court affirmed: record shows the court considered R.C. 2929.12 factors, found aggravating seriousness factors, acknowledged mitigating points but rejected them as justification, and did not impose an unlawful sentence

State v. Arnett, 88 Ohio St.3d 208 (2000) (trial court need not use specific language or make specific findings to show consideration of R.C. 2929.12)
State v. Marcum, 146 Ohio St.3d 516 (2016) (appellate review standard under R.C. 2953.08(G): reversal only if record clearly and convincingly shows sentence is unsupported or contrary to law)