State v. Nelson, 2022 Ohio 4308

Appellant Bryan K. Nelson pleaded guilty to three counts of gross sexual imposition against his minor daughters; two counts were third-degree felonies and one was a fourth-degree felony; two other counts were dismissed in exchange for the pleas.
Sentences imposed: 18 months (Count 2), 12 months (Count 3), and 48 months (Count 4), ordered to run consecutively for an aggregate 6.5 years in prison.
Nelson appealed only the consecutive-sentences order, arguing the trial court failed to make the statutory findings required by R.C. 2929.14(C)(4).
At sentencing the trial court stated it had analyzed consecutive sentences, found they were necessary to protect the public and to punish, that they were not disproportionate, and expressly relied on R.C. 2929.14(C)(4)(b) (multiple offenses as part of a course of conduct with unusually great harm).
The presentence investigation showed prolonged sexual abuse of three daughters beginning in elementary school, continuing for years, and one child ran away to escape the abuse; the court entered findings in the sentencing entry.

Issue	State's Argument	Nelson's Argument	Held
Whether the trial court erred by imposing consecutive sentences under R.C. 2929.14(C)(4)	The record and PSR support the court’s consecutive-sentence findings (necessity, non-disproportionality, and factor (b)); findings made at hearing and in entry	Record lacks evidence that harm was "so great or unusual" beyond typical psychological injury to victims; statutory findings unsupported	Affirmed: court engaged in required analysis; record supports necessity, proportionality, and (C)(4)(b) due to prolonged, severe abuse

State v. Beasley, 108 N.E.3d 1028 (Ohio 2018) (requires the three R.C. 2929.14(C)(4) findings and that they appear in both the sentencing hearing and entry)
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (no verbatim statutory recitation required but record must allow review to discern correct analysis)