State v. Bulger, 2020 Ohio 4602

Appellant Michael E. Bulger was indicted on multiple sex offenses for repeatedly sexually abusing his two stepdaughters over several years; one victim became pregnant at age 14 and bore Bulger’s child by DNA match.
Bulger pleaded no contest to one count of attempted rape (felony 2) and one count of rape (felony 1); remaining counts were dismissed per plea agreement.
At sentencing the trial court described the conduct as "particularly heinous," imposed 8 years for attempted rape and 11 years for rape, and ordered the terms served consecutively for an aggregate 19-year prison term.
The trial court made the findings required by R.C. 2929.14(C)(4) (necessity, proportionality, course of conduct, and great/unusual harm) and memorialized them in the entry.
Bulger appealed, arguing the 19-year sentence was excessive and contrary to R.C. 2929.11 because the court did not impose the minimum sanction needed for rehabilitation given his lack of education and learning disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 19-year sentence (including consecutive terms) is excessive/contrary to law under R.C. 2929.11 and 2953.08(G)(2)	State: Sentence is within statutory range; court considered sentencing purposes and made the required R.C. 2929.14(C)(4) findings supporting consecutive terms.	Bulger: Sentence is excessive; court should have imposed minimum sanctions aimed at rehabilitation (e.g., treatment, GED) because of his lack of education/learning disability.	Affirmed. The record supports the trial court's R.C. 2929.14(C)(4) findings; sentence is not contrary to law and consecutive terms were warranted given the course-of-conduct and severity.

State v. Gwynne, 158 Ohio St.3d 279 (2019) (Ohio Supreme Court clarified appellate review of aggregate consecutive sentences is limited to whether trial court’s findings under R.C. 2929.14(C)(4) are supported by the record)