State v. Fields, 2017 Ohio 661

On Jan. 30, 2015 Aaron S. Fields drove left of center, causing a collision that killed two occupants and seriously injured two others; his blood tested at four times the legal THC limit.
A Franklin County grand jury indicted Fields on 10 counts; he pled guilty to two counts of aggravated vehicular homicide (first-degree felonies) and two counts of aggravated vehicular assault (second-degree felonies); remaining counts were dismissed.
At sentencing (May 4–5, 2016) the trial court imposed consecutive terms: 7 years + 7 years + 3 years + 3 years (total 20 years), plus 180 days in a separate case to run concurrent.
Fields appealed, raising three assignments of error: (1) the court failed to make the statutory findings required for consecutive sentences under R.C. 2929.14(C)(4) and Bonnell, (2) the sentencing entry incorrectly stated defense counsel did not recommend a sentence, and (3) the judgment failed to award 336 days of jail-time credit.
The appellate court found the trial judge made the required consecutive-sentence findings at the hearing (though not verbatim), but failed to incorporate those findings into the written entry; it also found the jail-credit entry erroneous and remanded for nunc pro tunc correction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the R.C. 2929.14(C)(4) findings to impose consecutive sentences	State: Record shows the court made necessary findings at the sentencing hearing	Fields: Court failed to make statutorily required findings verbatim; sentencing entry lacks findings	The court held the oral findings satisfied Bonnell (verbatim language not required) but the written entry must be amended to incorporate those findings (remand for nunc pro tunc).
Whether the sentencing entry's statement that defense counsel did not recommend a sentence was erroneous and prejudicial	State: Entry meant to note there was no joint recommendation	Fields: Entry is factually incorrect because defense counsel did recommend eight years	The court held any misstatement was harmless; no prejudice shown, so assignment overruled.
Whether Fields was entitled to 336 days jail-time credit in the judgment entry	State: Agreed trial court erred in the written entry	Fields: The transcript and stipulation at sentencing established 336 days credit for 15CR-2099	The court sustained the assignment and remanded with instruction to correct the judgment entry to reflect 336 days credit.

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (oral findings at sentencing suffice if record shows correct analysis but sentencing entry must incorporate statutory findings; no talismanic recitation required)
State v. Moore, 161 Ohio App.3d 778 (Ohio Ct. App. 2005) (statutory findings overlap; courts may discern required findings from context and equivalent language)
State v. Underwood, 124 Ohio St.3d 365 (Ohio 2010) (sentencing court is not bound to adopt parties' recommended sentence)