State v. Jensen, 2026-Ohio-1729

Jensen was indicted on multiple sex offenses, later pleaded guilty to four counts of unlawful sexual conduct with a minor, and the State dismissed the remaining charges. 1
At the plea hearing, the court conducted a Crim.R. 11 colloquy, advised Jensen of his rights and potential penalties, and told him sentencing was not bound by the parties' recommendation. 2
At sentencing, the court considered the victim's long-term abuse, Jensen's minimization of culpability, the PSI, and the parties' statements. 3
The trial court imposed four 30-month prison terms to be served consecutively for an aggregate ten-year sentence plus five years of postrelease control. 4
Jensen appealed, arguing consecutive sentences were improper because the record showed he did not pose a risk to the public. 5
The appellate court reviewed the consecutive-sentencing findings, applied plain-error and clear-and-convincing standards, and affirmed. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were consecutive sentences supported by the record? 7	The State said the court made the required R.C. 2929.14(C)(4) findings.	Jensen said the record showed low recidivism and no public danger.	Affirmed; the findings were supported. 8

State v. Blanton, 2025-Ohio-237 (4th Dist. 2025) (appellate sentencing review is highly deferential 9)
State v. Glover, 2024-Ohio-5195 (4th Dist. 2024) (R.C. 2953.08(G) limits review of consecutive sentences 10)
State v. Hughes, 2025-Ohio-894 (4th Dist. 2025) (abuse-of-discretion review does not govern consecutive sentences 11)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (plain error is noticed only in exceptional circumstances 12)
State v. Long, 53 Ohio St.2d 91 (Ohio 1978) (plain error requires a manifest miscarriage of justice 13)
State v. Bonnell, 2014-Ohio-3177 (Ohio 2014) (consecutive-sentence findings must be made at sentencing and in the entry 14)
State v. Williams, 88 Ohio St.3d 513 (Ohio 2000) (sex-offender registration reflects public-safety and recidivism concerns 15)
State v. Wilson, 2013-Ohio-5195 (3d Dist. 2013) (maximum consecutive sentences upheld for repeated sexual abuse of a child 16)
State v. Hart, 2024-Ohio-4552 (1st Dist. 2024) (failure to cite sentencing statutes expressly does not show they were ignored 17)
State v. Cook, 2007-Ohio-625 (8th Dist. 2007) (uncharged acts may be considered at sentencing if not the sole basis 18)
State v. Cooey, 46 Ohio St.3d 20 (Ohio 1989) (uncharged crimes may be considered as part of a defendant's social history 19)