State v. Dodson, 2013 Ohio 1344

Dodson was charged in a 21-count indictment in 2011 for downloading child pornography using his home computer.
In 2012, Dodson pled no contest to counts 1-16 (illegal use of a minor), counts 17-19 (pandering), count 20 (unauthorized use of computer), and count 21 (criminal tools).
The trial court found Dodson guilty on all counts and sentenced him to 3 years on counts 1-19, 12 months on counts 20-21, with count 20 to run consecutively to count 1, totaling 4 years.
The court determined the offenses were not allied offenses of similar import for purposes of consecutive sentencing.
Dodson appealed arguing the court failed to make required HB 86 findings under R.C. 2929.14(C)(4) before imposing consecutive sentences.
The court’s sentencing journal entry inconsistently stated counts 19 and 20 in relation to consecutive terms, prompting remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court make required R.C. 2929.14(C)(4) findings for consecutive sentences?	State argues HB 86 findings were satisfied by the court's analysis.	Dodson contends the court failed to make mandatory consecutive-sentence findings.	No; findings lacking. Remanded for proper HB 86 findings.
Should the case be remanded to correct HB 86 findings and the journal entry discrepancy?	State requests correction and affirmation after proper findings.	Dodson requests proper HB 86 findings and consistent journal entry.	Remand to perform proper findings and correct the journal entry; judgment affirmed in part and vacated in part.

State v. Bonner, 8th Dist. No. 97747, 2012-Ohio-2931 (Ohio 2012) (consecutive-sentencing HB 86 analysis guidance)
State v. Walker, 8th Dist. No. 97648, 2012-Ohio-4274 (Ohio 2012) (remand for proper findings under HB 86)
State v. Edmonson, 86 Ohio St.3d 324, 1999-Ohio-110 (Ohio 1999) (statutory requirements satisfied by demonstrated analysis)
State v. Redd, 8th Dist. No. 98064, 2012-Ohio-5417 (Ohio 2012) (court's statements construed as findings when appropriate)