2025 Ohio 1654
Ohio Ct. App.2025Background
- John W. Long was indicted in two separate cases for sexually assaulting minor victims at two business locations, one in Independence, Ohio, and another in Shaker Heights, Ohio.
- The incidents in Shaker Heights occurred after Long had already been indicted for the Independence offenses.
- Long pleaded guilty to several counts of gross sexual imposition and a count of sexual battery after a motion for joinder was granted, and the remaining charges were nolled.
- The trial court imposed consecutive sentences across both cases totaling 12 years, citing public protection and proportionality, and designated Long as a Tier III sexual offender.
- Long appealed, challenging only the consecutive sentencing for the Independence case, arguing the findings under R.C. 2929.14(C)(4) were unsupported by the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether imposition of consecutive sentences in the Independence case complied with R.C. 2929.14(C)(4) | Consecutive sentences are justified; statutory findings made | Finding that offense was committed "while awaiting trial" unsupported for Independence case | Trial court's findings were sufficiently supported by the record; judgment affirmed |
Key Cases Cited
- State v. Bonnell, 2014-Ohio-3177 (Ohio 2014) (sentencing court must make statutory findings but need not state reasons at sentencing)
- State v. Hamrick, 2024-Ohio-5101 (Ohio Ct. App. 2024) (discussing sufficiency of findings under R.C. 2929.14 for consecutive sentences)
- State v. Alexander, 2013-Ohio-1987 (Ohio Ct. App. 2013) (multiple offenses can be across different cases for purposes of consecutive sentencing)