State v. Frederick, 2014 Ohio 1960

Thomas G. Frederick pled guilty to aggravated vehicular homicide (felony 2) and OVI (misdemeanor 1) after a September 29, 2012 crash that killed tow-truck driver William Houck.
Facts: Frederick struck a disabled vehicle on I-71; Houck was outside his tow truck and suffered fatal blunt-force injuries.
Officers found Frederick at the scene with a strong odor of alcohol; hospital blood test showed .242 BAC; Frederick admitted heavy drinking and said, "I killed someone."
At plea hearing the court advised maximum penalties (8 years for aggravated vehicular homicide; 6 months for OVI). Frederick pleaded guilty; a PSI was ordered.
At sentencing the court imposed consecutive sentences: 8 years (aggravated vehicular homicide) + 6 months (OVI), lifetime license suspension, and three years post-release control; the written entry stated the court considered R.C. 2929.11–.14 and made required findings.
Frederick appealed solely arguing the trial court erred by imposing maximum sentences without stating reasons on the record at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether imposition of maximum sentence without oral factual findings at sentencing violated statutory sentencing rules	State: sentencing entry shows court considered R.C. 2929.11/2929.12 and weighed required factors; no reversible error	Frederick: court failed to state basis for maximum sentence at oral sentencing; mitigators in PSI required on-the-record explanation	Court: Affirmed. Written entry sufficed; no statutory requirement for specific on-the-record findings for maximum sentences; sentence not contrary to law or plain error

(No officially reported authorities with reporter citations were cited in the opinion.)