State v. Dorsey, 2017 Ohio 138

Appellant Rico Dorsey pleaded guilty (Alford plea) to attempted felonious assault and abduction, both third-degree felonies.
At sentencing the trial court imposed maximum three-year terms on each count, to be served consecutively, and assessed bond forfeiture for failure to appear.
The state’s factual proffer: Dorsey grabbed and dragged the victim (his cohabitant), caused head injury, struck her, made her clean her own blood, and threatened to shoot her to prevent disclosure.
While the case was pending, Dorsey left Ohio; in Wisconsin he was convicted of strangulation/suffocation and domestic abuse.
Presentence report and court observed prior assaultive criminal history (multiple felonies and misdemeanors), prior community control and prison terms, denial of responsibility until sentencing, and attempted avoidance of prosecution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive maximum sentences were properly imposed under R.C. 2929.14(C)(4)	Dorsey: trial court abused discretion; facts do not support statutory findings for consecutive maximums	State: record (serious harm, criminal history, avoidance/denial) supports the court’s R.C. 2929.14(C)(4) findings	Court affirmed: record supports findings that consecutive sentences were necessary, not disproportionate, and that statutory subsections applied; sentence not contrary to law.

North Carolina v. Alford, 400 U.S. 25 (permits guilty plea while maintaining innocence)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make statutory findings for consecutive sentences but need not articulate them verbatim on the record)