State v. Brooks, 2016 Ohio 5685

Defendant Robert Brooks pleaded guilty to aggravated murder (merged counts), aggravated robbery, arson, kidnapping, and firearm specifications after a plea deal removing death-penalty specifications.
Victim Vivian Martin was killed and a fire set during a scheme to lure realtors to properties; Brooks received a life-without-parole sentence on the murder count plus concurrent terms on other counts and a consecutive firearm specification term.
At sentencing Brooks presented extensive mitigation evidence: service history, combat injuries, long-term treatment for severe PTSD, expert testimony that PTSD and an abusive childhood contributed to violent behavior, and criticism that VA care was inadequate.
The trial court stated on the record that it had considered R.C. 2929.12 generally and specifically subsection (F) regarding military service and service-related conditions, but declined to make more detailed or explicit written findings under subsection (F).
Brooks appealed, arguing the sentence was contrary to law because the trial court failed to make specific findings under R.C. 2929.12(F); the State argued the court had properly considered the statutory factor and formal findings were not required.
The Seventh District affirmed, holding the record showed consideration of R.C. 2929.12(F) and that the statute does not require explicit findings like those required by other sentencing provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court considered R.C. 2929.12(F) (military service and service‑traceable conditions) when sentencing	State: The court expressly stated it considered R.C. 2929.12(F); record supports consideration	Brooks: Court failed to properly consider the subsection when imposing life without parole	Held: Court did consider R.C. 2929.12(F); record shows consideration and mitigation evidence was presented
Whether the trial court was required to make explicit or written findings under R.C. 2929.12(F)	State: No statutory requirement for explicit findings; subsection parallels other R.C. 2929.12 factors that only must be considered	Brooks: Trial court erred by failing to make specific findings under subsection (F), requiring resentencing	Held: No explicit findings required under R.C. 2929.12(F); statute directs consideration but does not mandate formal findings, so sentence not contrary to law

State v. Belew, 140 Ohio St.3d 221, 2014-Ohio-2964, 17 N.E.3d 515 (Ohio 2014) (addressed R.C. 2929.12 timing issues and commentary regarding PTSD consideration)
State v. Bonnell, 140 Ohio St.3d 209, 2014-Ohio-3177, 16 N.E.3d 659 (Ohio 2014) (explains when trial courts must make statutory findings for sentencing)
Provident Bank v. Wood, 36 Ohio St.2d 101, 304 N.E.2d 378 (Ohio 1973) (statutory interpretation principle: apply unambiguous statute as written)
State ex rel. Savarese v. Buckeye Local School Dist. Bd. of Edn., 74 Ohio St.3d 543, 660 N.E.2d 463 (Ohio 1996) (statutory interpretation: plain language controls)
State ex rel. Francis v. Sours, 143 Ohio St. 120, 53 N.E.2d 1021 (Ohio 1944) (legislative intent and statutory construction principles)