State v. Bolden, 2025 Ohio 2010

Marvier Bolden, a juvenile, pleaded guilty to three counts, including aggravated robbery with a firearm specification, having weapons while under disability, and failure to comply with a police order, after a carjacking and police chase.
The trial court sentenced Bolden to a total of 60-78 months in prison, plus restitution, noting certain sentences as mandatory.
Bolden appealed, primarily arguing sentencing errors, including a misunderstanding of mandatory prison terms and community control eligibility.
The underlying controversy considers whether the trial court properly applied statutory sentencing factors, particularly for the failure to comply count.
The appeal also raised clerical errors in the sentencing journal and whether the restitution order was properly pronounced in open court.

Issue	Bolden's Argument	State's Argument	Held
Did the trial court misinterpret mandatory prison requirements for the failure to comply charge?	The court wrongly believed it had to impose prison if Bolden was sent to prison on other counts.	The imposed sentence was lawful.	The trial court erred; community control was permissible on this count regardless of other sentences.
Did the court consider community control sanctions before sentencing?	The court failed to adequately consider community control, especially for Count 7.	No requirement for more detailed record; court followed statutory process.	Remand required for clear and proper consideration of community control.
Were the proper statutory factors considered for the failure to comply charge?	The court failed to consider R.C. 2921.331(C)(5)(b) factors.	The court isn't required to detail consideration of these factors on the record.	No error; discussion of these factors was sufficient, but better practice is to reference them explicitly at resentencing.
Did discrepancies between oral sentencing and the journal entry warrant correction?	Journal entry errors require remand to match the oral pronouncement.	Any mistakes were typographical and can be remedied.	Moot due to full resentencing order.
Was restitution properly pronounced and imposed?	Restitution was not stated at sentencing, so should be vacated.	Restitution was part of plea agreement and validly imposed.	On remand, restitution must be addressed at resentencing.

State v. Paige, 153 Ohio St.3d 214 (courts may impose community control for one count concurrent to prison on another in same case)
State v. Logan, 2025-Ohio-1772 (prison is mandatory when a firearm specification attaches to a felony)
State v. Perry, 2015-Ohio-1542 (consecutive mandate for failure to comply does not create a prison term mandate)
State v. Robinson, 2022-Ohio-3033 (community control on one count cannot run consecutive to prison on another without statutory authority)
State v. Anderson, 2015-Ohio-2089 (proper approach to split sentencing)