State v. Biscardi, 2019 Ohio 4653

Paul A. Biscardi pled guilty in two separate Portage County cases to aggravated possession of drugs (both fifth-degree felonies), entered Nov. 29, 2016 and Feb. 21, 2017.
Each case carried a one-year prison term that the court suspended and placed Biscardi on five years of community control; the second sentence was ordered to run consecutive to the first if executed.
Probation filed violations (drug/alcohol use, failure to report, prohibited contacts) on Mar. 19, 2018; a revocation hearing was held Apr. 9, 2018.
The trial court revoked community control and imposed consecutive one-year prison terms (total two years) on Apr. 10, 2018, with 188 days credit; post-release control was optional up to three years.
The State conceded that the trial court omitted the additional statutory finding required by R.C. 2929.14(C)(4)(a)-(c) for consecutive terms and sought a remand, but the court found the appeal moot because Biscardi had completed his prison sentence before appellate review. Appeals were dismissed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by imposing consecutive sentences without making the additional R.C. 2929.14(C)(4)(a)-(c) finding	State concedes the trial court omitted the required subsection (a)-(c) finding but contends the record supports such findings and requests remand for a proper finding	Biscardi argues the consecutive sentences are contrary to law because the court failed to make the statutory subsection (a)-(c) finding required for consecutive terms	Court found the issue moot because Biscardi had already served the sentence; no relief available, so appeals dismissed

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make and incorporate R.C. 2929.14(C)(4) findings at sentencing to impose consecutive terms; no requirement to state supporting reasons)
State v. Berndt, 29 Ohio St.3d 3 (Ohio 1987) (appeals dismissed when they are rendered moot and no effective relief can be granted)