State v. Ford, 2017 Ohio 632

Defendant David Ford, previously convicted of kidnapping and attempted rape, committed new offenses after release and while on postrelease control for failing to notify a change of address.
Ford broke into a victim’s apartment, repeatedly punched her breaking her nose, forced her to perform oral sex, and then engaged in nonconsensual vaginal intercourse.
Ford pled guilty to rape, felonious assault, and aggravated burglary. The trial court imposed 11 years (rape), 8 years (felonious assault), and 11 years (aggravated burglary), to run consecutively for an aggregate 30-year term.
Ford challenged the consecutive sentences on appeal, arguing the trial court’s consecutive-sentence findings were unsupported by the record, citing a report recommending mental-health treatment rather than extended incarceration.
The trial court made the R.C. 2929.14(C)(4) findings at sentencing and incorporated them into its entry.
The appellate court affirmed, concluding the record supported the trial court’s findings and the sentence was within the statutory range.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were properly imposed under R.C. 2929.14(C)(4)	State: Trial court complied with statutory requirements and findings supported by record	Ford: Findings unsupported given his mental-health history and report recommending treatment	Affirmed — findings supported; consecutive sentences appropriate

Marcum, 146 Ohio St.3d 516 (2016) (standard of appellate review under R.C. 2953.08(G)(2) — courts may modify only if sentence is contrary to law or unsupported by the record)
Bonnell, 140 Ohio St.3d 209 (2014) (trial courts must make and incorporate R.C. 2929.14(C)(4) findings; reasons not required but record must show mandated analysis)
Brandenburg, 146 Ohio St.3d 221 (2016) (appellate modification limited to clear-and-convincing finding that sentence is contrary to law or unsupported by record)