State v. James
2017 Ohio 419
| Ohio Ct. App. | 2017Background
- Gary W. James, Jr. was indicted on three counts of rape and one count of kidnapping with a sexual-motivation specification based on sexual conduct with a 12‑year‑old victim.
- James pleaded guilty to one count of rape and one count of kidnapping (with sexual-motivation spec) on May 17, 2016.
- Trial court sentenced James to 10 years-to-life on the rape count and 15 years-to-life on the kidnapping count, ordered consecutively for an aggregate 25 years-to-life.
- Sentencing rationale emphasized grooming, travel with the victim (Ohio to Indiana), manipulation (instructions to mislead the victim’s father), lack of genuine remorse, and risk of recidivism.
- James appealed solely arguing the trial court erred in imposing consecutive sentences and that the record did not support the requisite statutory findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court legally imposed consecutive sentences under R.C. 2929.14(C)(4) | State: Trial court made the required findings and applied statutory factors; consecutive sentences were appropriate to punish and protect the public | James: Record lacks support for consecutive sentences; findings insufficient and sentence contrary to law | Court affirmed: record shows the court engaged in required analysis, made the statutory findings, and memorialized them in the entry; consecutive sentences upheld |
Key Cases Cited
- State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court need not recite statutory language verbatim but record must reflect required consecutive-sentencing analysis)