State v. Conklin, 2017 Ohio 7108

Appellant Shanan Conklin was indicted in 2015 on eight counts for criminal non-support of dependents; she pled guilty to two fourth-degree felonies (Counts 1 and 3) and the remaining counts were dismissed.
At sentencing (April 21, 2016) the court imposed consecutive maximum 18‑month terms on each count (36 months total).
Appellant was also serving community control from a 2008 non‑support case, admitted violation, and received a 180‑day sentence with credit for time served.
The trial court reviewed the presentence report, victim/third‑party statements, mitigation letters, and stated it considered R.C. 2929.11 and 2929.12 sentencing principles and factors.
The court noted appellant’s significant prior arrearages ($31,381.21 in 2008 growing to $51,234.02 by 2015) and prior contact with the court.
Appellant appealed, raising (1) that the 36‑month sentence violated R.C. 2929.11–.14 and due process as excessive/inconsistent; and (2) that the sentence was against the manifest weight of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by imposing consecutive maximum sentences in violation of R.C. 2929.11–.14 and due process	State: Trial court complied with sentencing statutes and considered required factors	Conklin: Sentence excessive, inconsistent with R.C. 2929.11–.14 and due process	Affirmed — court properly considered statutory factors; sentence not clearly and convincingly contrary to law
Whether the sentence was against the manifest weight of the evidence	State: Review governed by R.C. 2953.08 (statutory appellate review of sentences), not manifest weight standard	Conklin: Sentence is against manifest weight and therefore invalid	Affirmed — manifest weight standard inapplicable; appellant failed to show sentence unsupported or contrary to law

Mathis v. Ohio, 109 Ohio St.3d 54 (Ohio 2006) (trial court need not state factual bases for sentencing findings; consideration of sentencing statutes suffices)