State v. Chaney, 2016 Ohio 5437

Defendant Terry D. Chaney pleaded guilty to two counts of fourth-degree grand theft of a motor vehicle with elderly-victim specifications for stealing a 1958 Austin Healey and a 1950 Lincoln from a 78-year-old victim.
The trial court ordered a presentence investigation and gave Chaney time to pay $2,320 restitution; Chaney missed multiple scheduled sentencing dates and a capias issued after two failures to appear.
At sentencing, the court noted partial restitution payments but not full payment, recited Chaney’s extensive 30+ year criminal history (theft and violent offenses), and found he showed no genuine remorse.
The trial court imposed consecutive prison terms of 17 months on each count (34 months aggregate) and ordered restitution and costs.
Chaney appealed, arguing the court erred by failing to explicitly state its findings were made under R.C. 2929.14(C)(4) and that the record did not support the consecutive-sentence findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in imposing consecutive sentences by not explicitly citing R.C. 2929.14(C)(4) and by making findings unsupported by the record	State: Trial court made the required findings and engaged in proper analysis supporting consecutive terms	Chaney: Court failed to explicitly state findings were under R.C. 2929.14(C)(4) and the record does not support the findings	Court affirmed: explicit statutory citation not required; record (PSI, criminal history, victim harm, lack of remorse) supports R.C. 2929.14(C)(4) findings and consecutive terms

State v. Bonnell, 140 Ohio St.3d 209, 2014-Ohio-3177, 16 N.E.3d 659 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings but need not state reasons or use talismanic language)
State v. Rodeffer, 5 N.E.3d 1069 (2d Dist. 2013) (appellate review of felony sentencing follows statutory standard)