State v. Rammel, 2014 Ohio 1281

Rammel appeals re-sentencing in two cases after the prior void sentencing due to HB 86 application.
This court previously reversed and remanded for re-sentencing to apply HB 86; Rammel I and II addressed the void sentence issue.
Appellate counsel filed an Anders brief in both cases; Rammel did not file a pro se brief.
In 2010 CR 3732, the court imposed 36 months for burglary (HB 86) and 12 months for receiving stolen property, consecutive to the other case.
In 2011 CR 435, the court imposed multiple concurrent sentences (nine counts of receiving stolen property, burglary counts, and a breaking-and-entering count) with aggregating to a seven-year term when combined with the other case.
The court found HB 86-compliant findings, included post-release control, restitution, and costs, and concluded the re-sentencing complied with the law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
HB 86 compliance at re-sentencing	Rammel contends HB 86 was not properly applied.	State contends re-sentencing complied with HB 86.	HB 86 applied within statutory ranges; no error.
Consecutive-sentence findings under RC 2929.14(C)(4)	Rammel argues findings were insufficient or improper.	State asserts proper findings were made for consecutive sentences.	Findings satisfied statutory requirements; consecutive sentences valid.
Post-release control, restitution, and costs	Rammel challenges inclusion of PRC, restitution, and costs.	State contends these impositions were proper.	Post-release control, restitution, and costs properly imposed.

Anders v. California, 386 U.S. 738 (1967) (counsel may withdraw from appeal when no meritorious issues exist)