State v. King, 2019 Ohio 1492

Appellant Ricky Da'Anthony King was indicted in Dec 2017 for multiple drug offenses after police found hundreds of oxycodone pills and some cocaine.
At the time he was on supervised probation under an intervention in lieu of conviction (ILC) for separate felonies; his probation officer filed an ILC-violation notice based on the new charges.
In March 2018 King pleaded guilty to one second-degree felony count of aggravated possession of drugs and admitted the ILC violation; the state dismissed the other counts.
The trial court ordered a presentence investigation and, at the April 2018 hearing, imposed a mandatory six-year prison term for the aggravated-possession conviction and a concurrent prison term for the ILC violation.
King appealed only the aggravated-possession sentence, arguing the trial court failed to expressly consider the R.C. 2929.12 seriousness and recidivism factors at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court failed to consider R.C. 2929.12 factors before imposing sentence	King: court did not explicitly state consideration of R.C. 2929.12 at sentencing; remand needed	State: record and entry show the court considered sentencing principles and R.C. 2929.12	Court: affirmed — record (oral statements + written entry) shows required consideration; sentence not contrary to law

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard of appellate review under R.C. 2953.08 limits modification of felony sentences)
State v. McGowan, 147 Ohio St.3d 166 (Ohio 2016) (clarifies that R.C. 2953.08(G)(2) restricts appellate review and requires clear-and-convincing showing to vacate/modify a sentence)