State v. Gable, 2024 Ohio 293

Christopher Gable was convicted in two separate cases: nonsupport of dependents (Case No. 0764) and aggravated possession of drugs (Case No. 0413).
Gable was initially placed on community control in both cases, but subsequently violated the terms of his community control.
Upon violation, the trial court held a joint hearing, revoked his community control, and sentenced him to consecutive prison terms totaling 24 months.
Gable appealed, arguing that the court failed to make specific required findings on the record before imposing consecutive sentences.
The appeal concerned whether the trial court satisfied the statutory requirements for imposing consecutive sentences under Ohio law, specifically during the sentencing hearing.

Issue	Gable's Argument	State's Argument	Held
Whether the trial court properly imposed consecutive sentences by making requisite findings at the sentencing hearing	The trial court didn't state all necessary findings during the hearing, making the sentence contrary to law	The findings required were included in the written entry; oral recitation at hearing shouldn't be required	Reversed: Required findings must be made on the record at sentencing hearing, not just in the entry

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (holding trial courts must make statutory consecutive sentencing findings at the sentencing hearing and in the entry)
State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (sets standard for appellate review of felony sentences)
State v. Wood, 2020-Ohio-422 (holding failure to make required consecutive sentence findings at hearing is contrary to law)