State v. Eager, 2015 Ohio 3525

Indicted Oct. 16, 2014 on seven counts of gross sexual imposition (Counts 1–7).
Pled not guilty at arraignment; on Jan. 8, 2015 pleaded guilty to Counts 1–4 under a written agreement; Counts 5–7 dismissed.
Court accepted guilty pleas, sentenced to presentence investigation, and dismissed remaining counts on the same day.
On Feb. 20, 2015, trial court imposed four consecutive 3-year terms for Counts 1–4, totaling 12 years.
Eager filed a March 2, 2015 appeal challenging the consecutive-sentence framework under R.C. 2929.14(C)(4), arguing lack of evidence of great or unusual harm.
The court affirmed the trial court’s sentence; a dissent argued the record lacked support for great or unusual harm to justify consecutives.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were supported by great or unusual harm under R.C. 2929.14(C)(4)	Eager argues the record lacks evidence of great or unusual harm.	State contends the offenses were part of a course of conduct causing great or unusual harm to a child.	Consecutive sentences affirmed; record supported great or unusual harm.

State v. Ramos, 2007-Ohio-767 (Ohio 2007) (clear-and-convincing standard remains viable for appellate review of sentencing)
State v. Hites, 2012-Ohio-1892 (Ohio 2012) (requires explicit on-record findings before consecutive terms under R.C. 2929.14(C)(4))
State v. Bonnell, 2014-Ohio-3177 (Ohio 2014) (approved framework for reviewing consecutive-sentence findings; no talismanic language required)
State v. Sharp, 2014-Ohio-4140 (Ohio 2014) (requires findings to be incorporated in sentencing entry)
State v. Hale, 2014-Ohio-262 (Ohio 2014) (discussed in dissent regarding absence of victim-impact evidence)