State v. Marton, 2013 Ohio 3430

Marton pleaded guilty to 28 counts of pandering sexually oriented matter involving a minor and one count of possession of criminal tools, after a plea agreement reducing many charges.
Original indictment included 70 counts over four years; counts 1–68 were child pornography, count 69 amended to a child pornography charge, and count 70 was PCT.
At sentencing, the court imposed three-year terms on most counts and six months on the PCT, with counts 11 and 23 consecutive, others concurrent.
The court reopened a plea hearing to address a missed count and amended Count 69 and added Count 65, but failed to correct the journal entry memorializing the plea.
Marton challenged the consecutive sentences for lack of statutory findings under R.C. 2929.14(C)(4); the state conceded the error; the journal-entry defect and sentencing scheme led to remand for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the required findings for consecutive sentences	Marton contends the court failed to state statutory findings under R.C. 2929.14(C)(4).	Marton argues counsel should have objected to the consecutive terms; argument focuses on aiding appeal.	Consecutive-sentence findings were not adequately shown; error sustained and remanded.
Whether trial counsel was ineffective for not objecting to consecutive sentences	Marton contends counsel failed to object to improper consecutive sentences.	Counsel’s performance was reasonable given the law and negotiations; no prejudice shown.	No ineffective-assistance violation; record shows not deficient performance and no prejudice.

State v. Venes, 2013-Ohio-1891 (8th Dist. Cuyahoga 2013) (requires clear, not talismanic, statutorily mandated findings for consecutive sentences)
State v. Montgomery, 2009-Ohio-1276 (2d Dist. Montgomery 2009) (recognizes considerations in sentencing and effectiveness of counsel related to sentencing)