State v. Sprague, 2023 Ohio 4343

Appellant Joshua Sprague pleaded/was found guilty in three separate Lucas County cases: unauthorized use of a vehicle (felony 5), possession of a fentanyl-related compound (felony 5), and trespass in a habitation (felony 4) following multiple community-control violations.
Sprague repeatedly violated community control and participated intermittently in treatment programs; the court recited an extensive criminal history at sentencing.
On February 14, 2023 the trial court imposed consecutive prison terms: 11 months (CR-2018-3247), 11 months (CR-2021-1870), and 18 months (CR-2022-2076) — totaling 40 months — and informed Sprague of discretionary post-release control terms.
At the sentencing hearing the court stated that consecutive terms were necessary to protect the public and referenced Sprague’s community-control status and criminal history, but the transcript contains no explicit on-the-record proportionality (not-disproportionate) finding required by R.C. 2929.14(C)(4).
The written judgment entries, however, included the required consecutive‑sentence findings (including proportionality language) not spoken at the hearing.
The Sixth District reversed and remanded for resentencing because the trial court failed to make all R.C. 2929.14(C)(4) findings on the record at the sentencing hearing; the state’s cross-appeal regarding the length of discretionary post-release control was held moot by the remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the R.C. 2929.14(C)(4) findings at the sentencing hearing to impose consecutive terms	State: The hearing record demonstrates the court engaged in correct analysis and made required findings	Sprague: The court failed to make all required findings at the hearing—specifically the proportionality (not-disproportionate) finding	Reversed and remanded: court made some findings on the record but did not make the proportionality finding at the hearing; omission renders sentence contrary to law and requires resentencing
Whether Sprague’s CR-2021-1870 sentence included the correct discretionary post-release control term (up to 2 years)	State: Fifth-degree felony not subject to exceptions; discretionary post-release control term may be up to two years	Sprague: Court notified an incorrect (shorter) term (18 months)	Moot on appeal: issue rendered moot by reversal/remand for resentencing; no decision on merits

State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings at sentencing hearing; reasons not required verbatim)
State v. Beasley, 108 N.E.3d 1028 (Ohio 2018) (consecutive sentences require three statutory findings under R.C. 2929.14(C)(4))
State v. Elmore, 60 N.E.3d 794 (Ohio 2016) (proportionality finding entails judicial weighing/comparison of seriousness and danger)
State v. Gideon, 176 N.E.3d 720 (Ohio 2020) (appellate assignments of error can be moot when reversed/remanded and no longer live)