State v. Fauntleroy, 2012 Ohio 4955

Fauntleroy pleaded guilty to burglary, theft of firearms, and receiving stolen property; other charges were dismissed or merged.
He was sentenced to 36 months for burglary and 18 months for receiving stolen property, to be served consecutively for a total of 54 months.
HB 86 (2011) amended sentencing law to require specific consecutive-sentence findings under R.C. 2929.14(C)(4).
The trial court made extensive factual findings about past criminal history and risk, and stated reasons during sentencing for consecutive terms.
Fauntleroy’s sole assignment of error claimed the sentence violated R.C. 2929.14(C)(4) and related proportionality requirements.
The majority affirmed the sentence; one judge dissented arguing the statutory findings were not shown and remand was necessary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court make the required R.C. 2929.14(C)(4) findings for consecutive sentences?	Fauntleroy	Fauntleroy	Yes; findings satisfied despite lack of verbatim language
Are the consecutive sentences proportional and not contrary to law given the record?	State	Fauntleroy	Yes; sentences not disproportionate and consistent with record

State v. Jones, 2012-Ohio-2075 (Ohio 2012) (sufficient findings shown by conduct and history for consecutive sentences)
State v. Frasca, 2012-Ohio-3746 (Ohio 2012) (reverses need for exact statutory wording to justify consecutive sentences)
State v. Murrin, 2004-Ohio-3962 (Ohio 2004) (no talismanic words required; clear analysis suffices)
State v. Grissom, 2002-Ohio-5154 (Ohio 2002) (recitation of logic not required to be exact statute text)
State v. Green, 2005-Ohio-3268 (Ohio 2005) (no rigid recitation; proper analysis supports findings)