State v. McAndrew, 2017 Ohio 8993

Defendant Christopher T. McAndrew was indicted for abduction (F3) and domestic violence (F4); he pleaded guilty to the domestic-violence count and the abduction count was dismissed.
At sentencing the trial court imposed six months for the F4 domestic-violence conviction.
The court also revoked McAndrew’s post-release control (PRC) from an earlier case and imposed 1,264 days for the PRC violation to be served consecutively to the six-month term.
The PRC term represented the remaining time on supervision from a prior Ashland County case.
McAndrew appealed, arguing his sentence was not supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sentence (six months + 1,264 days consecutive for PRC violation) is supported by the record and lawful	State: R.C. 2929.141 authorizes revocation of PRC and mandates consecutive imprisonment for the PRC violation; trial court considered sentencing purposes and PSI	McAndrew: Sentence not supported by the record (argues sentencing inadequate or unsupported)	Court affirmed: R.C. 2929.141 authorizes and requires consecutive PRC sentence; no clear-and-convincing evidence that the record fails to support the sentence

State v. Foster, 845 N.E.2d 470 (Ohio 2006) (severed statutory judicial-fact-finding requirements; courts retain discretion to impose sentences within statutory ranges)
State v. Kalish, 896 N.E.2d 124 (Ohio 2008) (explains appellate review after Foster and requirement that trial courts consider R.C. 2929.11 and 2929.12)
State v. Mathis, 846 N.E.2d 1 (Ohio 2006) (addresses post-Foster sentencing and the role of statutory factors)
State v. Payne, 873 N.E.2d 306 (Ohio 2007) (further discussion of sentencing discretion post-Foster)