State v. Coleman, 2014 Ohio 5275

Appellant Darrell Coleman pled guilty in three Cuyahoga County cases after retracting not-guilty pleas.
Sentencing hearing occurred on December 27, 2013, with a recommended 30 years to life prison term in the plea.
In CR-13-571165-B, Coleman received life with parole after 30 years for aggravated murder, plus eight-year terms for two counts of aggravated robbery and involuntary manslaughter, all concurrent.
In CR-13-571726-A, Coleman received an eight-year aggravated robbery sentence to run consecutively to the CR-571165-B term.
In CR-13-572096-A, Coleman received four eight-year terms for aggravated robbery, concurrent to each other but consecutive to the other counts, for an aggregate life sentence with parole eligibility after 46 years.
Appellant challenged the consecutive-sentencing scheme for lacking on-record reasons; the court ultimately affirmed but remanded to correct journal entries.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences require court-stated reasons on the record	Coleman insists record-reason support is required	State contends Bonnell allows no such on-record reasons requirement	No on-record reasons required; Bonnell permits findings but not explicit reasons on record
Whether the findings necessary for consecutiveness were properly made	Findings were made but not reflected in journal entries	Findings were stated at sentencing and supported by the record	Findings were made and supported; journal entries must reflect them nunc pro tunc
Remedy for missing journal-entry findings	Appellant seeks reversal or resentencing	State seeks to preserve sentence as imposed	Remand for nunc pro tunc entries to include findings and comply with Bonnell

State v. Bonnell, 140 Ohio St.3d 209 (2014) (no requirement to state reasons on the record for consecutive sentences; findings must appear in journal entry)
State v. Venes, 992 N.E.2d 453 (8th Dist. Ohio, 2013) (concurrent vs. consecutive findings and record requirements recognized in 8th Dist.)