State v. Campbell, 2020 Ohio 3146

Appellant Chassidy Campbell pled guilty to receiving stolen property (4th-degree) and aggravated possession of drugs (5th-degree) after a plea agreement recommending an eight-month sentence.
The court accepted the plea, warned Appellant sentencing could exceed the recommendation, and released her on conditions including weekly random drug tests and appearing for sentencing on May 13, 2019.
Appellant arrived late, was ordered to submit to an immediate drug test, left the courthouse instead of complying, and a bench warrant issued; she was arrested May 23 and tested positive for methamphetamine, MDMA, and THC.
At sentencing the court found Appellant not amenable to community control, imposed 18 months for receiving stolen property and 6 months for drug possession, ordered the terms to run consecutively for an aggregate 24-month prison term.
Appellant appealed solely arguing the record did not support the sentence (including the upward departure from the plea recommendation); the Fourth District affirmed, finding the trial court’s findings supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by rejecting the eight-month recommended sentence and imposing a longer term	The State: court warned Appellant at plea; Appellant tested positive for drugs and fled courthouse—justifying a higher sentence	Campbell: her post-plea "poor choices" (panic, drug use, flight) do not justify a 16-month increase over the recommended 8 months	Court: No error; warnings at plea and Appellant’s conduct justified rejecting the recommendation (trial court has discretion)
Whether consecutive sentences were supported under R.C. 2929.14(C)(4)	The State: consecutive terms necessary to protect the public and supported by Appellant’s criminal history and conduct	Campbell: consecutive service is disproportionate and unsupported by the record	Court: Affirmed consecutive sentences; trial court made required statutory findings in the entry and record supports them

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (standard for appellate review of felony sentences)
State v. Foster, 845 N.E.2d 470 (Ohio 2006) (trial courts retain discretion within statutory ranges but must consider R.C. 2929.11 and 2929.12)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (consecutive-sentence findings must appear in the record; no requirement to state supporting reasons)
State ex rel. Duran v. Kelsey, 831 N.E.2d 450 (Ohio 2005) (trial court may impose a sentence greater than plea inducement if defendant was forewarned)
Cross v. Ledford, 120 N.E.2d 118 (Ohio 1954) (definition of clear and convincing evidence)