State v. McGee, 2013 Ohio 4926

Defendant Larry McGee pleaded guilty to breaking and entering (Count 1) and vandalism (Count 3); a grand-theft count was dismissed as part of the plea agreement.
The offenses involved removing and dismantling three rooftop air-conditioning units and stripping copper/aluminum parts from Federated Equipment Company.
At sentencing the trial court imposed the maximum terms: 12 months (Count 1) and 18 months (Count 3), to be served consecutively, and ordered $29,800 restitution.
The court discussed McGee’s extensive prior criminal history and stated a prison term was necessary to protect the public and to punish McGee; it said criminal history "requires consecutive sentences."
The state conceded the trial court did not expressly make the statutory findings required by R.C. 2929.14(C)(4) before ordering consecutive terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the required statutory findings before imposing consecutive sentences	State conceded the court did not make the enumerated R.C. 2929.14(C)(4) findings but argued the record supported them	McGee argued the court failed to make the required findings and thus consecutive sentences were improper	Court reversed and remanded: consecutive sentence vacated because the court failed to make the separate, statutory findings (record did not show required proportionality finding)

State v. Jones, 93 Ohio St.3d 391 (Ohio 2001) (trial court must make separate findings in support of sentencing decisions)
State v. Edmonson, 86 Ohio St.3d 324 (Ohio 1999) (court must engage in required analysis and select appropriate statutory criteria before imposing greater sentences)