State v. Hoy, 2024 Ohio 1555

Jonathan M. Hoy was indicted for multiple felony offenses across ten different cases between 2010 and 2022, including theft, drug possession, money laundering, assault, and having a weapon under disability.
Hoy pleaded guilty or had post-release control revoked in these cases and was sentenced in January 2023 to consecutive prison terms, totaling 138 months.
The sentencing court justified consecutive sentencing by citing Hoy’s lengthy criminal history, repeated violations of community control, and the seriousness of possessing a gun in the latest incident.
Hoy appealed, arguing that the trial court failed to make the statutory findings required under Ohio law (R.C. 2929.14(C)(4)) for imposing consecutive sentences.
The state argued that the trial court’s statements and the record supported the necessary findings for consecutive sentencing.
The appellate court reviewed the sentencing transcript and sentencing entries to determine compliance with statutory requirements for consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court make proper findings for consecutive sentences under R.C. 2929.14(C)(4)?	Hoy: Findings were deficient; no proportionality analysis made	State: The court's statements at sentencing and entries were sufficient	Court: Required findings not made; consecutive sentences vacated

State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court must make and incorporate findings for consecutive sentences, but a verbatim recitation is not required)
State v. Byrd, 2020-Ohio-507 (10th Dist.) (concurrent sentences presumed; exceptions require specific findings)
State v. Greene, 2018-Ohio-3135 (10th Dist.) (sentencing court must make statutorily-required findings for consecutive sentences)
State v. Fields, 2017-Ohio-661 (10th Dist.) (trial court's reference to seriousness of conduct may satisfy proportionality requirement)
State v. White, 2017-Ohio-7797 (7th Dist.) (similar findings sufficient for consecutive sentencing requirement)