Background

• On Jan. 12, 2015, Jamell Gaines argued with relatives, pointed a loaded handgun at his 12‑year‑old cousin, and police found cocaine and a gun under a mattress.
• A grand jury indicted Gaines on felonious assault, domestic violence, having weapons while under disability, and drug possession with multiple firearm and forfeiture specifications.
• Gaines pled guilty pursuant to a plea agreement to amended counts: aggravated menacing (misdemeanor), domestic violence (misdemeanor), having weapons while under disability (felony 3), and drug possession (felony 5); firearm specifications were nolled.
• The trial court ordered a PSI and TASC assessment, then sentenced Gaines to concurrent terms: 180 days (aggravated menacing), 180 days (domestic violence), 30 months (weapons while under disability), and 12 months (drug possession) — aggregate 30 months.
• Gaines appealed solely arguing the sentence was disproportionate, excessive, and that the court failed to properly consider R.C. 2929.11 and 2929.12 (purposes/principles and factors for felony sentencing).
• The appellate court affirmed, finding the sentence within statutory ranges and supported by the record; the court concluded the trial court considered required factors (reflected in the record and journal entry).

Issues

Key Cases Cited

• State v. Wilson, 951 N.E.2d 381 (Ohio 2011) (trial court need not use particular language or make specific findings on the record to show consideration of R.C. 2929.11 and 2929.12)
• State v. Foster, 845 N.E.2d 470 (Ohio 2006) (trial court has discretion to impose any sentence within statutory range without specific findings for maximums)
• State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (clarifies post‑Foster requirements for sentencing entries and appellate review)