State v. Moore, 2014 Ohio 765

Moore pled guilty to two counts of involuntary manslaughter and one count of obstructing justice; remaining charges were dismissed.
Sentencing occurred on June 3, 2013, with a aggregate term of 23 years and 6 months.
Trial court imposed consecutive sentences but did not expressly state the required statutory findings under R.C. 2929.14(C)(4).
Moore appealed alleging the consecutive-sentence findings were not made, rendering the sentence contrary to law.
The appellate court held the sentence is contrary to law due to missing consecutive-sentence findings and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were properly justified under R.C. 2929.14(C)(4).	Moore argues the court failed to make the required findings.	Moore contends no talismanic language is needed; findings must be on the record separately.	Consecutive-sentence findings were required and not properly made; remanded for resentencing.

State v. Stamper, 2013-Ohio-5669 (12th Dist. Butler 2013) (clarifies standard of review under R.C. 2953.08(G)(2))
State v. Crawford, 2013-Ohio-3315 (12th Dist. Clermont 2013) (abuse of discretion standard overridden by G2; governs felony sentences)
State v. Marshall, 2013-Ohio-5092 (12th Dist. Warren 2013) (consecutive-sentence findings must be separate from sentencing goals)
State v. Warren, 2013-Ohio-3483 (12th Dist. Clermont 2013) (requires three factors for consecutive sentences)
State v. Kuykendall, 2005-Ohio-6872 (12th Dist. Clermont 2005) (no talismanic language required for findings)
State v. McCoy, 2013-Ohio-4647 (12th Dist. Warren 2013) (discusses reasons for consecutive sentences under C(4))