State v. Feidler, 2024 Ohio 2040

Jeremy Feidler was indicted on one count of vandalism (4th-degree felony) and two counts of aggravated menacing (5th-degree felonies) in Trumbull County, Ohio.
Initial questions arose regarding Feidler’s competency to stand trial; after evaluation and treatment, he was found competent and entered guilty pleas to one count each of vandalism and aggravated menacing, with the other aggravated menacing charge dismissed.
Feidler was sentenced to 18 months for vandalism and 12 months for aggravated menacing, to be served consecutively (totaling 30 months).
He appealed, arguing the record did not support consecutive sentences.
The appellate court reviewed whether the trial court’s imposition of consecutive sentences was lawful and supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the record supports consecutive terms	Sentencing was lawful and supported by record	Imposing consecutive sentences not justified by evidence	Affirmed; record supports consecutive sentences
Whether court properly applied sentencing law	Trial court complied with R.C. 2929.14(C)(4)	Trial court failed to justify consecutive sentencing	Affirmed; proper statutory findings made
Constitutionality of appellate review limits	Ohio law’s limitations are constitutional	Review standard leaves sentences nearly unreviewable	Affirmed; appellate standard upheld
Whether alternative sanctions were required	Prison terms were warranted based on conduct	Court should have considered community control	Affirmed; choice of prison term not reviewable

State v. Lamb, 2023-Ohio-2834 (statute governs appellate review of felony sentences)
State v. Jones, 163 Ohio St.3d 242 (R.C. 2929.11 and 2929.12 are not reviewable for support by record)
State v. Bonnell, 140 Ohio St.3d 209 (trial court must make findings for consecutive sentences but need not state reasons)
State v. Haynes, 2022-Ohio-4464 (reviewing courts affirm consecutive sentences if statutory findings made)