State v. Morris, 2013 Ohio 1736

Morris pled guilty to burglary (2nd deg), felonious assault (2nd deg), and theft of credit cards (felony 5th) on Jan 11, 2011.
The court imposed a three-year term of community control with a condition to complete treatment at the W.O.R.T.H. center.
The joint sentencing agreement reserved consecutive prison terms if supervision was violated: 3 years for burglary, 3 years for felonious assault, and 11 months for theft, totaling 6 years 11 months.
In Sept. 2012, the State moved to revoke supervision; Morris admitted multiple violations including drug paraphernalia possession, failure to report, and cocaine use.
The trial court found a violation of community control and sentenced Morris to 6 years 11 months in prison, imposing the reserved terms consecutively.
Morris appeals, arguing the court failed to consider mitigating factors before issuing the sentence; the State contends the sentence was jointly recommended and not subject to review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused discretion by failing to consider mitigating factors before a joint sentence.	Morris argues no mitigating factors were considered.	Morris contends mitigating factors from R.C. 2929.12(C) were ignored.	Overruled; sentence upheld as jointly recommended and reviewable only for legal compliance.

Kryling, 2011-Ohio-166 (Ohio- 2011) (jointly recommended sentences protected from review)
Giesey, 2006-Ohio-6851 (Ohio- 2006) (authority on jointly recommended sentences)
Porterfield, 2005-Ohio-3095 (Ohio- 2005) (supreme court on joint sentencing expectations)
Townsend, 2009-Ohio-5664 (Ohio- 2009) (analysis of non-reviewability of jointly recommended sentences)
Wyche, 2007-Ohio-2784 (Ohio- 2007) (discusses review limits for jointly recommended sentences)