State v. Jackson, 2017 Ohio 7167

Edward R. Jackson committed three separate burglaries in 2015–2016 (a Cleveland Clinic office, a VA office, and a law office) and used stolen credit cards and devices.
Jackson pleaded guilty to burglary and identity-fraud counts across three case numbers in Cuyahoga County Common Pleas Court.
Presentence report showed an extensive 44-year criminal history with numerous burglary/theft convictions dating to juvenile conduct in 1973.
At sentencing the trial court imposed concurrent 18 months on the Cleveland Clinic case and consecutive three-year terms on the VA and law-office burglaries (total six years for those two cases).
Jackson appealed, arguing the trial court failed to state the statutory findings on the record required for consecutive sentences under R.C. 2929.14(C)(4).
The court of appeals affirmed the consecutive sentences but remanded for the trial court to incorporate the statutory findings into the written journal entry nunc pro tunc and to correct a clerical error in one entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court made the required R.C. 2929.14(C)(4) findings for consecutive sentences	State: Trial court’s oral statements show it made the necessary findings (protect public; not disproportionate; criminal-history basis)	Jackson: Sentence is contrary to law/due process because the court didn’t state requisite statutory findings on the record and/or in the journal entry	Court: Affirmed — oral findings were sufficient under Bonnell; record supports findings; remand to include findings in journal entry nunc pro tunc

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make and journal statutory findings for consecutive sentences; verbal statutory language not required verbatim)
State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard of review: appellate court may vacate/modify sentence only if clear and convincing evidence that record does not support trial court’s findings or sentence is contrary to law)