State v. Cade, 2013 Ohio 5162

Cade was convicted by jury of receiving stolen property and forgery involving a stolen credit card.
At sentencing, the trial court imposed maximum, consecutive twelve-month terms for two fifth-degree felonies.
The court discussed seriousness and recidivism factors under R.C. 2929.12 and noted Cade was on post-release control.
The written judgment indicated consideration of sentencing factors and post-release-control status in support of consecutive sentences.
On appeal Cade argued the court failed to make the required findings under R.C. 2929.14(C)(4) for consecutive sentences.
The court of appeals applied Kalish’s two-step standard to review the sentencing decision and found error requiring reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the required findings for consecutive sentences	Cade: findings under 2929.14(C)(4) were not made	State: findings can be inferred from remarks	Findings not properly made; reversal and remand required

State v. Kalish, 120 Ohio St.3d 23 (Ohio 2008) (two-step approach to reviewing felony sentences)
State v. Stevens, 2008-Ohio-5775 (2d Dist. Ohio) (framework for sentence-review and discretion)
State v. King, 2013-Ohio-2021 (2d Dist.) (requires explicit compliance with sentencing statutes for consecutive terms)
State v. Wills, 2013-Ohio-4507 (2d Dist. Montgomery) (findings for consecutive sentences must be explicit, not implicit)
State v. Venes, 2013-Ohio-1891 (8th Dist.) (warns against imputing findings from surrounding remarks)