State v. Brown, 2018 Ohio 4707

Richard G. Brown pleaded guilty in two Cuyahoga County cases to attempted felonious assault (with a one-year firearm specification), discharge of a firearm on/near prohibited premises, tampering with evidence, and improperly handling a firearm in a motor vehicle.
The trial court imposed a 12‑month sentence on the attempted felonious assault charge consecutive to the one‑year firearm specification; other counts in that case were concurrent.
In the separate case, the court imposed a six‑month sentence and ordered it to run consecutive to the first case.
The court entered consecutive‑sentence findings for Brown’s co‑defendant but failed to make the statutorily required R.C. 2929.14(C)(4) findings for Brown.
The court also ordered Brown to pay court costs; Brown asserted indigence and challenged imposition of costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by imposing consecutive sentences without required R.C. 2929.14(C)(4) findings	State argues the proper remedy is remand for the limited purpose of making the required findings	Brown argues the absence of findings requires vacating/modifying sentences to concurrent terms	Court sustained error; remanded for limited resentencing so court can decide whether to impose consecutive sentences and make required findings
Whether court erred in imposing court costs on an indigent defendant	State relies on R.C. 2947.23(A)(1) requiring costs be included in sentence	Brown contends his indigence (as previously found for appointed counsel) should bar costs or warrant waiver	Court overruled challenge: statutory duty to include costs exists; finding indigence for appointed counsel does not automatically waive costs; waiver is discretionary

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make and incorporate R.C. 2929.14(C)(4) findings when imposing consecutive sentences)