State v. Burns, 2018 Ohio 4657

David N. Burns, Jr. was indicted for violating a domestic violence protection order (felony 5) after leaving a hostile voicemail to his ex-wife on June 2, 2017; this was his second protection-order violation.
While awaiting trial on other charges, Burns pleaded guilty to forgery and was credited with time-served for that six-month sentence and discharged on December 4, 2017.
Burns remained in custody after December 4 because he awaited sentencing on the protection-order charge; he pled guilty to that charge on February 5, 2018.
At sentencing on February 22, 2018, the court imposed a nine-month prison term for the protection-order violation, awarded 80 days jail-time credit, and stated the nine-month term was being served "consecutively" to the earlier six-month sentence (which had already been completed).
Burns appealed, arguing (1) the trial court failed to make the statutory findings required for consecutive sentences under R.C. 2929.14(C)(4), and (2) the court miscalculated jail-time credit (awarded 80 days instead of 82).
The court of appeals affirmed: it held consecutive-sentence findings were not required because the earlier six-month sentence had already expired when the court pronounced the nine-month term, and the jail-time-credit claim was moot because Burns had already been released from custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by not making R.C. 2929.14(C)(4) findings before imposing consecutive sentences	State: consecutive structure was warranted given offense and criminal history (court found it appropriate)	Burns: court failed to make required consecutive-sentence findings, so sentence is contrary to law	Court: No error — statutory findings not required because the earlier six-month sentence had already expired; no consecutive sentence was actually imposed
Whether trial court miscalculated jail-time credit (80 days vs. 82 days)	State: award of 80 days was correct or not reviewable now	Burns: entitled to 82 days (claims sentencing date should have been Dec 2 not Dec 4)	Court: Moot — Burns already completed his nine-month sentence and released, so no justiciable relief available

State v. Marcum, 146 Ohio St.3d 516 (2016) (sets standard of appellate review for felony sentences under R.C. 2953.08(G)(2))
State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court must make required consecutive-sentence findings on the record, but need not state extensive reasons)
State ex rel. Compton v. Sutula, 132 Ohio St.3d 35 (2012) (an appeal challenging jail-time credit is moot once the sentence has been fully served)
State v. Murphy, 112 Ohio St.3d 329 (2006) (discusses mootness of appeals after sentence expiration)
State v. Clark, 119 Ohio St.3d 239 (2008) (postrelease-control sanctions and statutory limits on prison terms for violations)