State v. Brickles, 2021 Ohio 178

Indictment charged Brickles with two counts of OVI (fourth-degree felonies) and one count of failure to comply (third-degree felony); plea agreement: guilty to one OVI count and failure to comply; other OVI count dismissed.
Trial court sentenced Brickles to 30 months (OVI, with 60-day mandatory) and 36 months (failure to comply), ordered those terms consecutive to each other and to an existing Clark County sentence.
Brickles appealed, arguing the trial court failed to make the R.C. 2929.14(C)(4) findings on the record at the sentencing hearing before imposing consecutive sentences.
The court reviewed the appeal under the deferential R.C. 2953.08(G)(2) standard for felony sentences.
The sentencing entry contained written R.C. 2929.14(C)(4) findings, but the court’s oral pronouncement at the hearing did not explicitly include the required proportionality finding.
Court held that, under Bonnell, the trial court must make the R.C. 2929.14(C)(4) findings at the sentencing hearing (and incorporate them into the journal); failure to do so renders consecutive sentences contrary to law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court satisfied R.C. 2929.14(C)(4) when imposing consecutive sentences	State: the written sentencing entry contained the required R.C. 2929.14(C)(4) findings, supporting consecutive terms	Brickles: the court failed to make the required findings on the record at the sentencing hearing (oral pronouncement)	Court: Vacated sentences and remanded — oral findings did not adequately include the required proportionality finding; Bonnell requires findings at the hearing and in the entry

State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make and incorporate R.C. 2929.14(C)(4) findings at sentencing; no need to state reasons)
Cross v. Ledford, 120 N.E.2d 118 (Ohio 1954) (definition of clear-and-convincing evidence)
State v. Brewer, 11 N.E.3d 317 (4th Dist.) (discussion of appellate review under R.C. 2953.08)