State v. Hanlin, 2014 Ohio 5719

On April 16, 2013, David Hanlin Jr., David Hartman, and Carey Bailey Jr. confronted Zachary Willis and Demarcus Meeks; Bailey shot Willis multiple times, leaving him paralyzed. Hanlin remained in the car and later fled with co-defendants, hiding the car and two loaded firearms.
Hanlin was indicted for complicity to commit attempted murder (later dismissed as part of a plea), complicity to commit felonious assault (second-degree felony) with a three-year firearm specification, and tampering with evidence (third-degree felony).
Hanlin pleaded guilty to complicity to felonious assault, tampering with evidence, and the firearm specification pursuant to a plea agreement; the attempted-murder count was dismissed.
The trial court sentenced Hanlin to 6 years (felonious assault), a mandatory 3 years (firearm spec), and 30 months (tampering), ordered consecutively for a total of 11½ years.
Hanlin appealed, arguing the court failed to properly consider R.C. 2929.11/2929.12 factors and failed to make the required findings under R.C. 2929.14(C)(4) at the sentencing hearing for consecutive terms.
The Seventh District affirmed, finding the record shows the court considered the statutory sentencing factors and made the requisite consecutive-sentence findings at the hearing and in the entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court complied with R.C. 2929.11 and 2929.12 when imposing sentence	State: The court considered record, victim impact, and expressly stated it balanced seriousness and recidivism factors.	Hanlin: The court did not indicate consideration of the specific seriousness/recidivism factors or explain why "more serious" outweighed "less serious" factors.	Court: The sentencing entry and hearing demonstrate the court considered R.C. 2929.11 and 2929.12; no reversible error.
Whether the court made the R.C. 2929.14(C)(4) findings at the sentencing hearing to justify consecutive sentences	State: The trial court’s oral statements and written entry show consecutive terms were necessary, not disproportionate, and that offenses were part of one course of conduct with great/unusual harm.	Hanlin: The court failed to make the required statutory findings at the hearing (relying instead on the entry).	Court: The transcript contains explicit oral findings (harm is great/unusual; worst form of offense; tampering aggravated by leaving loaded guns), satisfying Bonnell; consecutive sentences affirmed.

Kalish, 120 Ohio St.3d 23 (Ohio 2008) (plurality sets two-step standard for appellate review of felony sentences: legality and abuse of discretion review)
Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings at the sentencing hearing and incorporate them into the entry; reasons are not required)