State v. Robinson, 2019 Ohio 2330

Defendant Michael Robinson pleaded guilty to a seven-count indictment: assault on a police officer; resisting arrest; having weapons while under disability; carrying a concealed weapon; improper handling of a firearm in a motor vehicle; receiving stolen property; and drug possession (Count VII), which included a one-year firearm specification.
The prosecutor told the court the State would have omitted the drug possession count if reindicted because lab tests on the suspected drugs were negative; nonetheless the State agreed to forego reindictment in exchange for Robinson’s guilty pleas to the existing indictment.
At the plea hearing Robinson acknowledged understanding the plea terms and denied coercion; he pleaded guilty knowingly and voluntarily despite the State’s admission about the lab results.
The trial court imposed an aggregate five-year prison term by running a 36-month sentence for having weapons while under disability consecutive to two years (one year for drug possession plus one year firearm spec); other counts were concurrent or resulted in time served.
Robinson appealed only the imposition of consecutive sentences, arguing the consecutive sentence on the drug-possession count lacked record support because the State conceded it could not prove that offense and thus the sentence was disproportionate and violated due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s findings supporting consecutive sentences are supported by the record under R.C. 2929.14(C)(4)	The State argued the court made the required statutory findings considering the defendant’s overall course of conduct, criminal history, and that consecutive terms were necessary to protect the public	Robinson argued the lab results showed he did not commit Count VII, so imposing consecutive time tied to that conviction is unsupported, disproportionate, and violates due process	Court affirmed: sentencing court lawfully considered defendant’s conduct as a whole, made the statutory findings, and defendant’s voluntary plea forecloses his challenge (invited error)

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (sets appellate standard of review for felony sentences under R.C. 2953.08(G)(2))
State ex rel. Bitter v. Missig, 648 N.E.2d 1355 (Ohio 1995) (invited error doctrine: a party cannot complain of an error it induced)