State v. Parrish, 2012 Ohio 3153

Parrish was involved in a 2011 crash that killed two passengers and injured others while driving under the influence; he was charged in a 16-count indictment.
Defendant pled guilty to aggravated vehicular homicide (two counts), aggravated vehicular assault, and one OVI count after plea negotiations that removed certain enhancements.
The offenses included multiple counts with license suspension aggravators and one count amended to include additional victims.
The trial court sentenced Parrish on September 30, 2011, the effective date of Am.Sub.H.B. 86, with a lengthy sentencing hearing.
The court imposed two consecutive two-year terms for the two AVH counts, plus concurrent terms for AVA and OVI counts, along with a lifetime license suspension, post-release control, and a $1,000 fine.
Parrish appeals asserting (1) improper consecutive-sentence findings under R.C. 2929.14(C)(4) and (2) ineffective assistance of counsel for not raising that issue at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences complied with 2929.14(C)(4).	Parrish argues consecutive terms lacked required statutory findings.	Parrish contends the court failed to make specific findings when imposing consecutive terms.	The court complied with 2929.14(C)(4) and made proper findings.
Whether counsel was ineffective for not arguing the specific findings were required.	Parrish contends counsel failed to press the need for explicit findings.	Counsel strategically emphasized a minimum sentence; no prejudice shown since statute complied.	No merit; ineffective-assistance claim denied because findings were satisfied and prejudice shown none.

State v. Calliens, 8th Dist. No. 97034, 2012-Ohio-703 (8th Dist. 2012) (requires fact-finding for consecutive sentences under Am.Sub.H.B. 86)
State v. Wilson, 8th Dist. No. 85598, 2005-Ohio-4285 (8th Dist. 2005) (exemplifies proper consideration of deterrence and public protection in sentencing)