State v. Chapman, 2013 Ohio 2161

Thomas Chapman was convicted in three 2009 cases for burglary and drug-possession offenses with sentences including community-control sanctions and a prior release from imprisonment;
In 2012 he pleaded guilty to heroin possession and to illegally conveying drugs into River City and received incarceration for these offenses;
The trial court revoked the three prior community-control sanctions and imposed new prison terms, ordering them to be served consecutively for a total of 19 years;
On appeal Chapman contends the court failed to make the required statutory findings under R.C. 2929.14(C)(4) before imposing consecutive sentences;
Appellate court recognizes the revived statutory requirement for three-step analysis and specific findings before consecutive sentences;
The court vacates the consecutive portions and remands for resentencing with proper findings, affirming other judgments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with R.C. 2929.14(C)(4) before imposing consecutive sentences.	State concedes the court did not make the required findings.	Chapman contends the court failed to perform the statutorily mandated analysis.	Yes; the consecutive sentences are vacated and remanded for proper findings.

State v. Jones, 2012-Ohio-2075 (1st Dist. 2012) (reasserted three-step analysis for consecutive sentences under 2929.14(C)(4))
State v. Alexander, 2012-Ohio-3349 (1st Dist. 2012) (identified required findings and record sufficiency for consecutive sentences)
State v. Cowins, 2013-Ohio-277 (1st Dist. 2013) (vacatur of consecutive sentences lacking statutory findings)
State v. Erkins, 2012-Ohio-5372 (1st Dist. 2012) (consecutive sentences without findings are contrary to law)
State v. Kalish, 120 Ohio St.3d 23 (2008) (addressed statutory findings for consecutive sentences)