State v. DiGrino, 2019 Ohio 3992

DiGrino was indicted on three fifth-degree felony drug-possession counts and placed on community control with a 180-day jail term and treatment conditions.
He missed multiple court dates; warrants issued. After a bench trial he was found guilty and sentenced to community control in April 2017.
Community-control violations led to progressive sanctions; a visiting judge on August 24, 2018 found violations, terminated probation contingent on the defendant reporting to jail on Aug. 27 for a 90-day county-jail sanction.
DiGrino failed to report; a warrant issued. At a subsequent hearing the original trial judge vacated the visiting judge’s order and imposed three consecutive 12‑month prison terms.
DiGrino appealed, arguing (1) the trial court lacked jurisdiction to vacate the termination and resentence and (2) the court failed to make the statutory findings required for consecutive sentences.
The court affirmed jurisdiction and notice but held the consecutive-sentence finding was legally insufficient and reversed and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to vacate probation termination and resentence; adequacy of notice	State: Termination was conditional on reporting; failure to report left DiGrino on post‑release control so court retained jurisdiction; arrest warrant gave adequate notice	DiGrino: The August 24 order terminated probation so trial court lost authority; he lacked proper notice of the proceeding	Court: Jurisdiction retained because termination was conditioned on reporting and DiGrino failed to report; notice adequate; assignment lacks merit
Statutory findings for consecutive sentences under R.C. 2929.14(C)(4)	State: Consecutive terms were necessary and not disproportionate given multiple violations	DiGrino: Trial court failed to make the required R.C. 2929.14(C)(4) findings at the sentencing hearing and in the entry	Court: The oral statement was insufficient to satisfy Bonnell; reversed and remanded for resentencing to make and journalize the required findings or impose concurrent terms

State v. Bonnell, 140 Ohio St.3d 209, 2014-Ohio-3177, 16 N.E.3d 659 (Ohio 2014) (trial court must make required consecutive-sentence findings at the sentencing hearing and incorporate them into the judgment entry; failure to make findings at the hearing requires remand)
State v. Cozzone, 114 N.E.3d 601 (11th Dist. 2018) (appellate court applying Bonnell; failure to make statutory findings at sentencing hearing mandates remand)