State v. Hammond, 2013 Ohio 3727

Defendant Paris J. Hammond (a juvenile at the time of the offense) was indicted on 10 counts including attempted murder, multiple felonious assaults, firearm specifications, and related offenses; plea agreement reduced charges.
Hammond pled guilty to two amended counts of felonious assault (Counts 2 and 4) with three-year firearm specifications; other counts were nolled or deleted.
Trial court sentenced Hammond to merged three-year firearm specification and consecutive prison terms on the two felonious-assault convictions, resulting in an aggregate 18-year sentence.
At sentencing the court reviewed the presentence investigation report and victim impact statements, discussed Hammond’s criminal record, gang membership, and the severity of the victim’s injuries (paralysis, organ damage, shattered tailbone).
Hammond appealed, arguing the trial court imposed consecutive sentences without making the statutory findings required by R.C. 2929.14(C)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the R.C. 2929.14(C)(4) findings required to impose consecutive sentences	The court adequately considered PSI, victim impact, defendant’s record, and discussed seriousness and community impact, justifying consecutives	The court failed to make the separate, statutorily required findings (necessity, proportionality, and at least one statutory predicate) on the record before imposing consecutive terms	Reversed and remanded for resentencing because the record does not show the trial court made the required R.C. 2929.14(C)(4) findings before imposing consecutive sentences

State v. Kalish, 896 N.E.2d 124 (Ohio 2008) (discussed standard of appellate review of sentences in post-Foster context)
Kraly v. Vannewkirk, 635 N.E.2d 323 (Ohio 1994) (plurality opinions and precedential value discussion)