State v. Ferrell, 2011 Ohio 1180

Appellant Ferrell appeals his misdemeanor sentence after pleading no contest to operating without a license (minor misdemeanor) and failure to stop after an accident (first-degree misdemeanor).
Charges originally included driving on a suspended license and failure to stop after an accident; plea admitted to reduced offenses with restitution payable to the victim.
Sentence imposed: 60 days in jail, a $500 fine, restitution, and three years of probation, with intensive probation as a community-control sanction.
Appellant did not provide a sentencing transcript; the state did not file a brief after appellate briefing.
Court presumes the trial court properly considered the statutory sentencing criteria since the judgment entry states the court considered them, and the record shows a substantial compliance with R.C. 2929.21–22.
Judgment affirmed, with no transcripts on appeal and no reversible error shown on the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly considered misdemeanor sentencing purposes.	Ferrell argues the court failed to consider R.C. 2929.21–22 factors.	Ferrell contends lack of explicit on-record consideration of factors requires reversal.	Affirmed; presumed compliance with statutory criteria.

State v. Crable, 2004-Ohio-6812 (7th Dist.) (trial court must consider factors; absence of explicit findings not fatal if within limits; presumption of proper consideration governs)
State v. Gill, 2010-Ohio-5525 (7th Dist.) (overriding purposes; consider 2929.22 factors)
State v. Hause, 2009-Ohio-548 (12th Dist.) (guidance on sentencing factors; relevance to procedure)
State v. Brooks, 2006-Ohio-4610 (7th Dist.) (discusses Foster and no need for maximum findings; on-record findings not required for non-maximum)
State v. Best, 2009-Ohio-6806 (7th Dist.) (presumption of consideration from silent record; community-control sanctions implied)