State v. Schaus, 2024 Ohio 1515

Michael Schaus was indicted on 15 counts of pandering obscenity involving a minor, pleading guilty to 10 counts as part of a plea agreement.
The trial court sentenced Schaus to 18 months on each count, with sentences to be served consecutively for a total of 180 months (15 years).
At sentencing, the court cited Schaus's extensive criminal history, the number of illicit images, and noted he was on postrelease control when the offenses occurred.
The trial court’s sentencing entry cited statutory factors but failed to expressly make all the findings required by R.C. 2929.14(C)(4) for consecutive sentences at the sentencing hearing.
Schaus appealed solely on the imposition of consecutive sentences, arguing the trial court did not make the required statutory findings.

Issue	Schaus's Argument	State's Argument	Held
Whether the trial court made all required R.C. 2929.14(C)(4) findings at the sentencing hearing	Required findings, particularly the proportionality analysis, were not made on the record	References to seriousness/recidivism factors were sufficient for findings; findings can be inferred from the record	Trial court did not make all required findings, especially proportionality; sentence reversed and remanded

State v. Bonnell, 2014-Ohio-3177 (clarifies required findings for consecutive sentences)
State v. Marcum, 2016-Ohio-1002 (defines standard for clear and convincing evidence)
State v. Johnson, 2021-Ohio-2254 (application of R.C. 2929.14(C)(4) findings)
State v. Sprague, 2023-Ohio-4343 (court must specifically address proportionality in consecutive sentencing)