State v. Ghazi, 2019 Ohio 339

Ahmed Ghazi was indicted in 2007 on multiple drug charges arising from three undercover transactions (sale of crystal methamphetamine and sales/offers of pseudoephedrine) occurring over several months in 2006–2007.
After indictment Ghazi posted bond, absconded to the Middle East, and returned in 2016 to surrender; he pled no contest in December 2016.
Trial court originally imposed an aggregate term of 5 years 6 months, including consecutive terms; this sentence was reversed on appeal for failure to make required R.C. 2929.14(C)(4) findings and remanded for resentencing.
At resentencing the court considered the PSI, counsel’s and Ghazi’s statements, and recidivism/seriousness factors, and reimposed the same aggregate 5 years 6 months sentence with consecutive terms.
Ghazi appealed, arguing the consecutive sentences were not supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court properly imposed consecutive sentences under R.C. 2929.14(C)(4)	State: trial court made the statutory findings at hearing and in entry; record supports findings	Ghazi: record does not support imposition of consecutive terms	Affirmed — court found findings were made and supported by the record

Marcum v. State, 146 Ohio St.3d 516 (2016) (sets standard of appellate review for felony sentences under R.C. 2953.08(G)(2))
Bonnell v. Ohio, 140 Ohio St.3d 209 (2014) (requires trial court to make R.C. 2929.14(C)(4) findings at sentencing and incorporate them into the entry)