State v. Hairston, 2017 Ohio 8719

Christopher B. Hairston pled guilty in 2016 to third-degree felony domestic violence and was placed on community control with a stated prison sanction of 36 months if he violated.
In 2017 he pled guilty to fourth-degree felony menacing by stalking arising while on probation for the domestic-violence case.
At a combined hearing the trial court revoked community control and sentenced Hairston to 36 months for the domestic-violence revocation and 18 months for the menacing-by-stalking, ordered to run consecutively (total 54 months).
Hairston appealed, arguing the trial court failed to make the statutory R.C. 2929.14(C)(4) findings required for consecutive sentences.
The trial court's oral pronouncement said consecutive sentences were "not disproportionate to the circumstances," but did not expressly reference the required finding that they were not disproportionate to the danger the offender poses to the public, and the written entries omitted any R.C. 2929.14(C)(4) findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the required R.C. 2929.14(C)(4) findings at sentencing to impose consecutive sentences	State: The court's statements and the record, read as a whole, encompass the required findings; any omission is not plain error	Hairston: The court failed to make the full disproportionality finding (specifically re: danger to the public) and failed to incorporate findings in the journal entries	Reversed and remanded: Court did not make the complete disproportionality finding at the hearing and did not incorporate findings into the entries; resentencing required

State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial courts must make R.C. 2929.14(C)(4) findings at sentencing and incorporate them into the judgment entry; no requirement to state reasons)
State v. Sergent, 148 Ohio St.3d 94 (2016) (absent an order requiring consecutives, sentences run concurrently; courts may impose consecutive terms under R.C. 2929.14(C)(4))