State v. Jackson, 2015 Ohio 5114

Appellant Michael A. Jackson II was convicted by jury of murder, two kidnapping counts, and felonious assault, with associated firearm specifications, after a trial in Franklin County Court of Common Pleas.
The offenses arose from a October 26, 2013 incident at a Carbondale Road residence where Davis (appellant's brother) and others attacked Dylan Stewart and Gaston; Gaston was killed and Stewart was wounded.
Appellant allegedly aided and participated with Davis in restraining Stewart and Gaston at gunpoint, while Davis shot Gaston and Stewart was shot in the leg.
Davis later killed Gaston and then committed suicide after authorities located him; Gaston’s body was wrapped and disposed of with controlled efforts to conceal the crime.
The jury acquitted appellant of aggravated murder counts but found him guilty of the remaining charges; three three-year firearm specifications attached to those counts were included, with one-year firearm spec on felonious assault.
The trial court sentenced Jackson to a total term of 29 years to life, with murder plus firearm specification to run consecutively and other terms to run concurrently, and no concurrent-consecutive adjustments discussed at length in the findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency and weight of the evidence	Jackson argues the evidence is legally insufficient and against the manifest weight.	Jackson contends the witnesses’ credibility undermines the verdicts.	Convictions not against weight or sufficiency; credible evidence supports murder, kidnapping, felonious assault with accomplice liability.
Consecutive sentences—statutory findings	The court failed to properly justify consecutive sentences under R.C. 2929.14(C)(4).	The court’s reasoning was sufficient or at least the findings were implicit in the record.	Plain error found; reverse and remand for proper findings and resentencing to reflect R.C. 2929.14(C)(4) requirements.

Bonnell v. Bonnell, 140 Ohio St.3d 209 (2014) (consecutive-sentence findings must be incorporated in sentencing entry)
State v. J.H.S., 2015-Ohio-254 (10th Dist. 2015) (lack of explicit findings requires remand for proper findings)
State v. Williams, 2015-Ohio-1136 (10th Dist. 2015) (plain-error review for sentencing findings when not objected to)
State v. Hillman, 2014-Ohio-5760 (10th Dist. 2014) (preservation and incorporation of findings in sentencing entry)
State v. Spires, 2011-Ohio-3312 (10th Dist. 2011) (weight of the evidence and witness credibility in appellate review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review in criminal cases)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (sufficiency and weight distinction in appellate review)