State v. Dixon, 2015 Ohio 5277

On Nov. 14, 2013, Dixon and accomplices entered a Columbus home, tied a cognitively delayed 15‑year‑old (M.M.) to a chair, and Dixon pointed a shotgun at him while they stole property. Appellant called his grandmother to pick him up; police arrested them carrying stolen goods.
A Franklin County grand jury indicted Dixon on multiple counts including aggravated burglary, robbery, kidnapping, and theft, each with firearm specifications.
Dixon pleaded guilty to aggravated robbery with a firearm specification and kidnapping; the remaining counts were nolled.
The trial court sentenced Dixon to 8 years for aggravated robbery, a consecutive 3‑year firearm specification, and 8 years for kidnapping — consecutive for a 19‑year aggregate term.
Dixon appealed, arguing the trial court failed to make the statutory findings required for consecutive sentences and thus violated Ohio sentencing statutes and his due process rights.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Dixon)	Held
Whether trial court made required R.C. 2929.14(C)(4) findings before imposing consecutive sentences	Trial court’s statements at sentencing show it addressed necessity, proportionality, and (C)(4)(b) factors; record supports findings	Trial court failed to make the factual findings necessary to impose consecutive terms under R.C. 2929.14(C)(4)	Court held the transcript shows the three required findings were made at the hearing; consecutive sentences upheld
Whether aggregate 19‑year sentence is contrary to law for failure to consider R.C. 2929.11(A) purposes/principles	Trial court expressly considered R.C. 2929.11 and 2929.12 at hearing and in entry; sentence not contrary to law	Court failed to consider/ weigh R.C. 2929.11(A) factors; sentence unlawful	Court held the sentencing hearing and entry demonstrate consideration of the statutory purposes; sentence not contrary to law
Whether omission of statutory findings from written judgment renders sentence invalid	State: failure to include findings in entry is clerical and correctable by nunc pro tunc entry per Bonnell	Dixon: omission means entry does not reflect required findings, rendering sentence defective	Court affirmed sentence but remanded for nunc pro tunc entry to incorporate the on‑the‑record R.C. 2929.14(C)(4) findings

State v. Bonnell, 140 Ohio St.3d 209 (2014-Ohio-3177) (trial court must make R.C. 2929.14(C)(4) findings on the record; written entry must incorporate them, and omissions can be corrected by nunc pro tunc entry if the findings were made at sentencing.)