State v. Cox, 2016 Ohio 20

Denitra Cox pleaded guilty to multiple counts arising from harm to her three minor children: one second-degree felony child endangering (medical neglect of her son), two felony abductions (against two daughters), and two misdemeanor child endangerings; sentencing totaled 14 years (consecutive terms).
Trial court imposed consecutive sentences, explaining they were necessary to protect the public, to punish Cox, and noting separate victims, dates, ages, and the parent–child relationship.
Cox appealed, arguing (1) the trial court failed to make the statutory findings required for consecutive sentences under R.C. 2929.14(C) and (2) the court should have merged allied offenses of similar import.
The court of appeals reviewed whether the trial court’s statements satisfied the Bonnell standard (finding need not be verbatim if the record shows the correct analysis).
On merger, the court applied the Ruff test for allied offenses (dissimilar import, separate victims or times, or separate animus) and also addressed forfeiture/plain error under Rogers and Quarterman.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court made required R.C. 2929.14(C)(4) findings for consecutive sentences	Trial court demonstrated the required analysis: protection of public/punishment, not disproportionate, and that harm to multiple victims was great/unusual	Cox argued the court failed to expressly find consecutive sentences were not disproportionate, so findings were inadequate	Court affirmed: statements sufficiently show the court engaged in correct analysis under Bonnell; findings discernible from record
Whether allied-offense merger required (R.C. 2941.25 / Ruff)	State: offenses involved separate victims, separate acts, or occurred at different times, so they do not merge	Cox argued some counts were allied and should merge; she did not object at trial (forfeited except for plain error)	Court affirmed: offenses were committed against separate victims or at different times/acts, so Ruff criteria show no merger; no plain error shown

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court need not recite statutory language verbatim; appellate court must be able to discern required findings)
State v. Ruff, 143 Ohio St.3d 114 (Ohio 2015) (test for allied offenses: dissimilar import, separate victims/times, or separate animus)
State v. Rogers, 143 Ohio St.3d 385 (Ohio 2015) (plain-error review for sentencing and allied-offense claims)
State v. Quarterman, 140 Ohio St.3d 464 (Ohio 2014) (procedural forfeiture of sentencing errors clarified)
Gregg v. Georgia, 428 U.S. 153 (U.S. 1976) (Eighth Amendment proportionality principle discussed)
Coker v. Georgia, 433 U.S. 584 (U.S. 1977) (Eighth Amendment bars punishments grossly disproportionate to the crime)