State v. Garcia, 2014 Ohio 1538

Garcia was indicted on Possession of Heroin and Possession of Cocaine, both fifth-degree felonies, for January 2013 conduct.
She entered a plea agreement; State recommended community control with drug treatment, and trial court sentenced her to 12 months (heroin) and 8 months (cocaine), to be served consecutively (total 20 months).
Garcia appealed challenging the imposition of consecutive sentences.
The trial court stated consecutive service was necessary to protect the public and punish the offender, and found the sentences not disproportionate, citing Garcia’s criminal history and drug use.
The appellate court reviewed under RC 2929.14(C)(4) and affirmed, concluding the findings were supported and not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were proper	Garcia argues the court abused its discretion by imposing consecutive sentences on low-level, victimless drug possession counts.	State contends findings under RC 2929.14(C)(4) were properly made and supported by the record to impose consecutive sentences.	Consecutive sentences affirmed; findings supported; no abuse of discretion.

State v. Rodeffer, 2013-Ohio-5759 (2d Dist. Montgomery 2013) (addresses standard of review for consecutive sentences)
State v. Temple, 2013-Ohio-3843 (2d Dist. Clark 2013) (court not required to articulate talismanic words; must reflect statutory findings)
State v. Hubbard, 2013-Ohio-2735 (10th Dist. Franklin 2013) (clarifies sentencing findings necessity)
State v. Fahl, 2014-Ohio-328 (2d Dist. Clark 2014) (discusses standard of review for sentences)