State v. Bonnell, 2012 Ohio 5150

Bonnell pled guilty to a fifth-degree fel. count of tampering with coin machines and three third-degree burglary counts under a negotiated plea (Dec 6, 2011).
Sentencing on Jan 6, 2012 imposed 11 months for tampering and 30 months for each burglary, with all four terms run consecutively and restitution of $2,837 ordered.
HB 86 (effective Sept 30, 2011) amended R.C. 2929.14(C)(4) to require specific findings before imposing consecutive sentences.
Trial court issued consecutive-sentence findings and stated it considered PSI and Bonnell’s extensive criminal history.
PSI documented numerous theft-related offenses and prior prison terms; court described Bonnell’s record as atrocious and found the burglaries did not merge.
Court affirmed Bonnell’s sentence on appeal; Hoffman dissented, would remand for HB 86–compliant resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences complied with R.C. 2929.14(C)(4).	Bonnell contends the court failed to make proper statutory findings.	Bonnell argues HB 86 requires more explicit factual findings supporting consecutive terms.	Findings supported the consecutive sentences; judgment affirmed.

State v. Comer, 99 Ohio St.3d 463 (2003 Ohio) (relinquished pre-Foster requirements; explains comparative duty to articulate reasons not required post-Foster)
State v. Alexander, 2012-Ohio-3349 (1st Dist. 2012) (discusses sufficiency of findings under 2929.14(C)(4))
State v. Frasca, 2012-Ohio-3746 (11th Dist. 2012) (supports flexibility in noting findings without talismanic words)
State v. Murrin, 2004-Ohio-3962 (8th Dist. 2004) (consecutive-sentence analysis without verbatim statutory language)
State v. Jones, 2012-Ohio-2075 (1st Dist. 2012) (consecutive-sentence findings sufficient if supported by record)
State v. Green, 2005-Ohio-3268 (11th Dist. 2005) (no need for magic words; record must show proper analysis)
State v. Grissom, 2002-Ohio-5154 (11th Dist. 2002) (early authority on non-talismanic language)