State v. Patterson, 2018 Ohio 4114

On May 19, 2016, Alonzo Patterson shot and killed Diamond Russell; he and a co-defendant were indicted on multiple counts including aggravated murder, murder, attempted murder, and related weapons and tampering offenses.
Patterson pleaded guilty pursuant to a plea agreement on May 8, 2017, to amended counts: involuntary manslaughter with a 3-year firearm specification, two counts of attempted murder each with 3-year firearm specifications, tampering with evidence, and carrying a concealed weapon; remaining counts dismissed.
The plea included a joint sentencing recommendation from the parties for an aggregate term between 23 and 30 years.
At sentencing, the court heard victim impact, mitigation, and arguments from the prosecutor (for 30 years) and defense (for the low end of the range); PSI and mitigation reports were prepared.
The court imposed an aggregate sentence of 25 years (concurrent and consecutive components consistent with statutory firearm specification requirements and the judge’s exercise of discretion); Patterson received 393 days’ jail credit.
Patterson appealed, arguing the trial court failed to make required consecutive-sentence findings under R.C. 2929.14(C)(4) and failed to consider/reflect mitigating factors under R.C. 2929.12(E) in the journal entry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate review is available for a sentence that was jointly recommended by the parties	State argues the sentence is authorized by law and jointly recommended, so not reviewable under R.C. 2953.08(D)(1)	Patterson argues the court failed to make statutorily required consecutive-sentence findings and failed to consider/reflect mitigating factors	Court held sentence was authorized by law, jointly recommended, and imposed by the judge; under R.C. 2953.08(D)(1) the sentence is not subject to appellate review, so affirmed

None with official reporter citations (opinion relies on unpublished/state appellate dispositions without official reporter citations).