State v. Murrill, 2019 Ohio 3318

In Feb. 2018 a Butler County grand jury indicted Mickey Murrill on 25 sexual-offense counts involving multiple children known to him.
In Sept. 2018 Murrill pled guilty to 10 offenses, including rape (first-degree), kidnapping with a sexual-motivation specification (first-degree), and other sex offenses and misdemeanors.
At sentencing the trial court imposed indefinite prison terms: 15 years-to-life for rape and 10 years-to-life for kidnapping, ordered consecutively; other counts were merged or run concurrently, producing an aggregate sentence of 25 years-to-life.
The court designated Murrill a Tier III sex offender and advised him on parole and five-year postrelease control.
On appeal Murrill argued the trial court erred by imposing consecutive sentences without making the required statutory findings under R.C. 2929.14(C)(4), asserting the court merely adopted the prosecutor’s statements rather than making independent findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were lawful under R.C. 2929.14(C)(4)	State: trial court made the required findings at the hearing and in the entry; consecutive sentences are lawful	Murrill: court failed to independently make the statutory findings and merely acquiesced to prosecutor’s recitation	Court: Findings were made at the hearing and entered; recitation need not be verbatim; consecutive sentences upheld
Whether trial court must recite statutory language verbatim	State: no talismanic incantation required; court must show correct analysis and record support	Murrill: omission of specific statutory phrase undermines validity	Court: Bonnell permits nonverbatim findings if record shows correct analysis; permissible here
Whether record supports factual bases for consecutive findings	State: record (multiple victims, serious/unusual harm) supports finding that single term inadequate	Murrill: challenges sufficiency of record to support findings	Court: record supports findings; court referenced six victims and harm; findings not contrary to law
Whether prosecutor’s prompting invalidates findings	State: court expressly adopted the omitted phrase after prosecutor noted it; court made its own finding	Murrill: reliance on prosecutor’s prompt shows lack of independent judicial finding	Court: ministerial incorporation after prompting is insignificant where the court clearly engaged in analysis; sentence valid

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standards for appellate review of felony sentences under R.C. 2953.08)
State v. McGowan, 147 Ohio St.3d 166 (Ohio 2016) (appellate-scope limits for modifying sentences)
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial courts need not recite statutory language verbatim; reviewing court must be able to discern the required findings)
State v. Beasley, 153 Ohio St.3d 497 (Ohio 2018) (explaining R.C. 2929.14(C)(4) requirements for consecutive sentences)