State v. Davis, 2017 Ohio 775

Appellant Jed P. Davis II was indicted on tampering with evidence (third-degree felony) and possession of drug abuse instruments (first-degree misdemeanor). The misdemeanor was later dismissed as part of plea proceedings.
On July 7, 2016, Davis withdrew his not-guilty plea and pled guilty to tampering with evidence under R.C. 2921.12(A)(2).
A presentence investigation (PSI) documented Davis’s long history of substance abuse and an extensive criminal record (61 entries).
At sentencing (Aug. 29, 2016) Davis and his counsel spoke and requested help for addiction; the trial court acknowledged the PSI and Davis’s addiction but emphasized public protection and punishment.
The trial court imposed a 36-month prison term (within the statutory range for a third-degree felony) and Davis appealed, arguing the court failed to comply with R.C. 2929.11 and 2929.12.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with R.C. 2929.11 and 2929.12 in sentencing	Davis: Court failed to consider his efforts/request for treatment and relevant statutory sentencing factors	State: Court considered PSI, purposes of sentencing, and balanced seriousness/recidivism factors	Court: Affirmed — record shows court considered R.C. 2929.11 and 2929.12; sentence within statutory range and not contrary to law

State v. Kalish, 120 Ohio St.3d 23, 896 N.E.2d 124 (2008) (framework for reviewing whether a sentence is contrary to law and guidance that consideration of statutory factors, even without specific language, is sufficient)
State v. Arnett, 88 Ohio St.3d 208, 724 N.E.2d 793 (2000) (trial court not required to use specific words or make detailed findings to show it considered R.C. 2929.12 factors)