State v. Dover, 2019 Ohio 2462

Dover was indicted in two Clark County cases: receiving stolen property (fourth-degree felony) and attempted murder with a firearm specification (first-degree felony).
Pursuant to a plea agreement, Dover pled guilty to receiving stolen property and to one count of attempted murder with a firearm specification; other charges were dismissed and a presentence investigation (PSI) was ordered.
At sentencing the trial court reviewed the PSI and imposed 1 year for receiving stolen property, 11 years for attempted murder (maximum), and 3 years for the firearm specification, to be served consecutively for an aggregate 15-year term.
The trial court made the consecutive-sentence findings required by R.C. 2929.14(C)(4) at the hearing and in the journal entry.
Dover appealed, arguing the record did not support consecutive sentences or the length of the aggregate sentence, emphasizing his lack of adult convictions and non-violent juvenile history.
The PSI showed an extensive juvenile adjudication history spanning multiple years and offenses, some occurring shortly before the adult offenses at issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were supported by the record under R.C. 2929.14(C)(4)	State: Trial court made required findings and could consider juvenile record; consecutive sentences necessary to protect public and proportionate	Dover: No adult criminal record and only non-violent juvenile offenses, so record does not support (C)(4)(c) finding	Affirmed. Court found required findings made; extensive juvenile history supports (C)(4)(c) and consecutive sentences
Whether aggregate 15-year sentence is supported by the record	State: Sentences are within statutory ranges and supported by facts (shooting, fleeing in stolen vehicle, gang involvement, threats)	Dover: Aggregate length not supported given his background	Affirmed. Individual sentences lawful and record supports aggregate under clear-and-convincing standard

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (standard of review for felony sentences under R.C. 2953.08(G)(2))
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings but need not state reasons)
State v. Rodeffer, 5 N.E.3d 1069 (Ohio App. 2013) (explaining deferential review: appellate court must clearly and convincingly find record fails to support sentencing findings)
State v. Venes, 992 N.E.2d 453 (Ohio 2013) (interpretation of R.C. 2953.08 standard referenced in sentencing review)
State v. Withrow, 64 N.E.3d 553 (Ohio App. 2016) (affirming consecutive sentences where juvenile record supported criminal-history finding)