State v. Pringle, 2024 Ohio 137

Jeffrey Pringle was convicted after pleading guilty to three counts of rape of victims under age thirteen, three counts of gross sexual imposition of a victim under thirteen, and one count of gross sexual imposition by force or threat of force, with sexually violent predator specifications.
The sexual abuse involved two minor victims and occurred over several years. Pringle admitted to the conduct during the police investigation.
Pringle was sentenced by the trial court to ten years to life on each rape count, 36 months to life for each gross sexual imposition count, and 18 months for the count involving force or threat; sentences on two rape counts were to run consecutively (totaling 20 years to life), with the rest concurrent.
Pringle appealed, challenging only the consecutive sentencing on two rape counts.
The appellate review involved Ohio's standard for review of felony sentencing and specifically the requirements for imposing consecutive sentences.

Issue	Appellant's Argument	State's Argument	Held
Did the trial court err in imposing consecutive sentences for two counts of rape?	Consecutive sentences not supported by record; he expressed remorse, was elderly/ill, with a low-risk assessment and no criminal history.	Consecutive sentences were necessary given length, manner, and harm of the abuse, and Pringle's position of trust; required findings were made and supported by evidence.	Affirmed; trial court's findings met statutory requirements and were supported by the record.

State v. Marcum, 146 Ohio St.3d 516 (standard of appellate review for felony sentencing under Ohio law)
State v. Bonnell, 140 Ohio St.3d 209 (requirements for making and recording findings for consecutive sentences)
State v. Roberts, 2020-Ohio-6722 (appellate role and review standards for felony sentencing)