State v. Black, 2014 Ohio 5570

Chester L. Black, Jr. was indicted on two counts of rape (first-degree felonies) and twelve counts of sexual battery (third-degree felonies); he pleaded guilty to ten sexual-battery counts pursuant to a plea agreement that dismissed the rape counts and two sexual-battery counts.
At sentencing the trial court imposed one year in prison for each sexual-battery count and ordered the ten one-year terms to run consecutively, for a total of ten years.
The trial court made the required consecutive-sentence findings orally at the sentencing hearing.
The written sentencing entry stated only: “Consecutive sentences are necessary and appropriate for the reasons articulated in open court,” and did not expressly incorporate the statutory R.C. 2929.14(C)(4) findings.
Black appealed solely arguing that the trial court’s failure to incorporate its consecutive-sentence findings into the written entry was reversible error.
The appellate court affirmed the sentence but remanded for the trial court to correct the sentencing entry via a nunc pro tunc order to expressly incorporate the findings made on the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to incorporate R.C. 2929.14(C)(4) findings in the written entry requires reversal	State: Oral findings at sentencing were made; failure to recite findings verbatim in entry is a clerical error that can be corrected by nunc pro tunc.	Black: The court erred by not incorporating its consecutive-sentence findings into the sentencing entry, requiring reversal.	The court held oral findings were made and remediable by nunc pro tunc; lack of explicit findings in the entry is not reversible error when made on the record.

State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings at sentencing and incorporate them into the sentencing entry; reasons need not be stated; clerical omission may be corrected by nunc pro tunc)