State v. Ruff
2017 Ohio 4340
Ohio Ct. App.2017Background
- Appellant, Ronald Ruff, was indicted on cocaine possession, weapons under disability, and receiving stolen property, based on a 2015 incident.
- In 2016 Ruff pleaded guilty to cocaine possession and an amended aggravated assault charge; two charges were dismissed.
- The plea resulted in concurrent or consecutive sentences for two felonies: 11 months and 17 months, to be served consecutively.
- The trial court imposed consecutive terms citing public protection, punishment, serious injury to the victim, and Ruff’s prior criminal history.
- Ruff timely appealed challenging the legality of the consecutive sentences under R.C. 2929.14(C)(4).
- The appellate court analyzed the three-step test for consecutive sentences and affirmed the sentence as not contrary to law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether consecutive sentences were proper under R.C. 2929.14(C)(4). | Ruff contends the two low-level felonies do not justify consecutive terms. | State argues the court properly applied the three-step analysis and found necessity and proportionality. | Consecutive sentences affirmed; findings supported by record per Bonnell and related cases. |
Key Cases Cited
- State v. Bonnell, 140 Ohio St.3d 209 (2014-Ohio-3177) (no need to state reasons, just recite findings in entry; required analysis complete)
- State v. Jude, 2014-Ohio-3441 (6th Dist. Lucas No. L-13-1185) (recitation of findings supported by record suffices)
- State v. Banks, 2014-Ohio-1000 (6th Dist. Lucas No. L-13-1095) (three-step analysis for consecutive sentences; stepwise requirements)
- State v. Payne, 2014-Ohio-1147 (6th Dist. Lucas Nos. L-13-1024, L-13-1025) (foundations for review under R.C. 2953.08(G)(2))