State v. Bryan, 2017 Ohio 1532

Between Nov. 16, 2015 and Apr. 6, 2016, Michael S. Bryan sold cocaine and methamphetamine to a confidential informant; police raided his residence Apr. 7, 2016.
Bryan was indicted on five counts of drug trafficking (one cocaine, four methamphetamine); two school specifications were later dismissed.
On Sept. 21, 2016 Bryan pled guilty to the five counts; he waived a presentence investigation and acknowledged the court could impose consecutive sentences.
At sentencing the State requested an aggregate 10-year term; defense requested an aggregate 4-year term. The court rejected community control and imposed 24 months on each count to be served consecutively for an aggregate 10 years.
The sentencing entry (Oct. 21, 2016) reflected the ten-year aggregate, but the court did not make on the record the specific statutory finding required by R.C. 2929.14(C)(4)(a)–(c).
Bryan appealed, arguing the trial court failed to make the requisite consecutive-sentence findings; the State conceded the omission. The appellate court vacated the consecutive sentences and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly imposed consecutive sentences without making the specific statutory finding required by R.C. 2929.14(C)(4)(a)–(c)	State: consecutive sentences necessary to punish/protect given pattern of conduct; appellate brief conceded the specific (a)–(c) finding was not made	Bryan: court failed to make the required R.C. 2929.14(C)(4) finding(s) at sentencing or in the entry, rendering consecutive terms contrary to law	Court: reversed and remanded — trial court made the general findings (necessity and proportionality) but did not make any of the three statutory (a)–(c) findings on the record or in the entry; consecutive sentences vacated and case remanded for resentencing

State v. Bonnell, 140 Ohio St.3d 209 (trial court must make R.C. 2929.14(C)(4) findings at sentencing and incorporate them into the entry; reasons need not be given)