State v. Pettorini, 2021 Ohio 1512

June 20, 2019: appellant involved in a crash, found unconscious and revived with Narcan; fentanyl recovered; indicted for aggravated possession (19 CR 839).
May 1, 2020: appellant fled a traffic stop in a high-speed pursuit, ran stop signs/signals, abandoned vehicle, and was arrested; used syringes found in the vehicle; indicted for failure to comply with police and possession of drug abuse instruments (20 CR 205).
Superseding indictment added a failure-to-appear count in 19 CR 839, later dismissed by the State on September 8, 2020.
On September 8, 2020, appellant pleaded guilty to the remaining counts and was sentenced to 3 years in 20 CR 205 and 1 year in 19 CR 839, ordered consecutively for a 4-year aggregate term.
The trial court relied on appellant’s being on supervision/under indictment when offenses occurred, his failure to appear, drug-involved conduct, and an extensive criminal/drug history; the court found him not amenable to community control.
Appellant appealed, arguing the court erred by imposing prison rather than community control and by ordering consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prison (not community control) was proper	Trial court properly imposed prison because appellant was on supervision/under indictment, failed to appear, and was not amenable to community control	Pettorini: remorse, relapse into addiction, and lack of organized trafficking warrant community control	Affirmed — court considered R.C. 2929.11/2929.12; failure to appear and supervision status supported prison term
Whether consecutive sentences were lawful	Consecutive terms were necessary to protect the public and to punish; statutory findings were made under R.C. 2929.14(C)(4)	Pettorini: consecutive sentences are disproportionate and unlawful	Affirmed — court made the required consecutive-sentence findings; PSI and criminal history support consecutive terms; Bonnell standard met

State v. Marcum, 59 N.E.3d 1231 (explains standard of review for felony sentences under R.C. 2953.08)
State v. Bonnell, 16 N.E.3d 659 (explains requirement to make R.C. 2929.14(C)(4) findings at sentencing and to include them in the entry; no separate statement of reasons required)