State v. Carmichael, 2017 Ohio 8904

Adam Carmichael was indicted for domestic violence (elevated to a felony based on prior convictions), abduction, and obstructing official business; a Crim. R. 29 motion was granted on the obstructing count, and a jury convicted on the domestic violence and abduction counts.
Four independent eyewitnesses testified that Carmichael grabbed, slammed, kicked, and struck his wife, Kristina, and that she screamed for help; two police officers later observed Carmichael holding Kristina by the neck in front of him as a human shield.
Kristina denied that Adam assaulted her at trial, attributed some injuries to others who intervened, and testified she fell and he kept picking her up; she had previously reported (and later declined to prosecute) a domestic-violence incident in May 2016.
Officers tased and arrested Carmichael after a confrontation in which he taunted officers to shoot him while holding his wife in front of him; Kristina had visible injuries consistent with assault.
At sentencing the court considered the presentence report showing multiple prior violent convictions, imposed consecutive maximum prison terms (two 3-year terms to run consecutively), and made the required statutory findings for consecutive sentences on the record and in the entry.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Carmichael)	Held
Sufficiency / manifest weight of the evidence challenging convictions	Eyewitness and officer testimony overwhelmingly support convictions for domestic violence and abduction	Convictions argued to be unsupported/against manifest weight (raised by appellate counsel as potential issue)	Court: No arguable merit. Weight and credibility of eyewitness and officer testimony support convictions; Kristina's denials were discredited. Convictions affirmed.
Sentencing: whether sentence is clearly and convincingly contrary to law	Sentence within statutory ranges; court made requisite findings for consecutive terms and considered statutory factors	Sentence argued to be unsupported/contrary to law (raised as potential issue)	Court: No arguable merit. Trial court made required findings, included them in entry, and had discretion to impose maximum consecutive terms within statutory range; sentence affirmed.

Anders v. California, 386 U.S. 738 (1967) (framework for appellate counsel to file a brief asserting no nonfrivolous issues)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (standards for manifest-weight review)
State v. Marcum, 146 Ohio St.3d 516 (2016) (standard for appellate review of felony-sentencing claims under R.C. 2953.08(G))
State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court not required to state reasons for consecutive-sentence findings in judgment entry)
State v. King, 992 N.E.2d 491 (2013) (trial court has discretion to impose any sentence within statutory range without additional findings to impose maximum)