State v. Campbell, 2023 Ohio 4597

Orion A. Campbell was charged with multiple counts, including four counts of Unlawful Sexual Conduct with a Minor and one count of Corrupting Another with Drugs, relating to his conduct with a victim aged 13-14.
Campbell pleaded guilty to those charges as part of a plea agreement; a tampering with evidence charge was dismissed.
At sentencing, the court considered Campbell’s criminal history, including prior rape and various offenses involving minors, as well as his status as a registered sex offender and high recidivism risk.
The trial court imposed consecutive sentences, finding them necessary to protect the public and not disproportionate to the conduct at issue.
Campbell appealed, arguing the trial court failed to make specific required findings for consecutive sentencing under Ohio law.
The appellate court found the trial court’s findings, though imperfect, sufficient and affirmed the consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Propriety of Consecutive Sentences	Court made adequate findings for consecutive sentences under the statute	Campbell argued that the trial court failed to make the required proportionality finding and record did not support consecutive sentences	The appellate court held the findings were adequate, the record supported the consecutive sentences, and affirmed the judgment

State v. Bonnell, 140 Ohio St.3d 209 (standard for making consecutive sentencing findings)
State v. Marcum, 146 Ohio St.3d 516 (standard for appellate review of felony sentences)
State v. Cozzone, 2018-Ohio-2249, 114 N.E.3d 601 (no need for word-for-word recitation as long as findings are discernible)