State v. Horobin, 2015 Ohio 5300

Defendant Mark D. Horobin lived with the Jackson family while trying to stop using heroin; on December 10, 2014 he took the family van, electronics and gift cards without permission and did not return.
Horobin was indicted and tried by jury on grand theft (motor vehicle) and theft (over $1,000); convicted on both counts in March 2015.
At sentencing the trial court imposed consecutive prison terms (18 months + 12 months = 30 months total).
At the sentencing hearing the court referenced Horobin’s lengthy theft history, poor compliance with supervision, lack of cooperation with the presentence investigation, and that the theft deprived a family of transportation at Christmas.
The sentencing entry repeated similar reasons but did not expressly make the statutory findings required by R.C. 2929.14(C)(4).
On appeal Horobin challenged only the imposition of consecutive sentences, arguing the trial court failed to make the required findings on the record and in the judgment entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly imposed consecutive sentences under R.C. 2929.14(C)(4)	The State argued the court made sufficient findings (court noted defendant’s long theft history, noncompliance, and impact on victims) justifying consecutive terms	Horobin argued the court failed to make the specific statutory findings required by R.C. 2929.14(C)(4) and did not incorporate them into the sentencing entry	Court reversed and remanded: trial court did not make the required R.C. 2929.14(C)(4) findings on the record and in the entry; remand for proper consideration and to enter required findings

State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must state the statutory findings required by R.C. 2929.14(C)(4) at sentencing and incorporate them in the judgment entry; no talismanic words required but the record must show the required analysis)