State v. Spencer, 2014 Ohio 204

Randy Spencer pleaded guilty to five counts of fifth-degree felony criminal nonsupport for owing $46,784.38 in child support.
Trial court sentenced him to 12 months on each count and ordered the sentences to run consecutively, calling the case “one of the worst examples of criminal nonsupport.”
Spencer appealed, challenging the consecutive sentences as contrary to law for failure to make required statutory findings under R.C. 2929.14(C)(4).
The State conceded that the trial court did not make the statutory findings required for consecutive sentences.
The Eighth District applied its prior rulings requiring distinct, statutory findings on the record before imposing consecutive sentences.
The court reversed and remanded for resentencing because the trial court failed to make the required R.C. 2929.14(C)(4) findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court lawfully imposed consecutive sentences without making the findings required by R.C. 2929.14(C)(4)	State conceded the court erred (no required findings).	Spencer argued consecutive sentences were invalid because the court did not make the statutory, separate findings.	Reversed and remanded: court failed to make the required R.C. 2929.14(C)(4) findings; resentencing required.

State v. Venes, 992 N.E.2d 453 (Ohio App. 2013) (R.C. 2929.14(C)(4) requires separate, on-the-record findings before imposing consecutive sentences)
State v. Edmonson, 715 N.E.2d 131 (Ohio 1999) (trial court need not use exact statutory language but must perform required sentencing analysis and select statutory criteria)