State v. Sprott, 2017 Ohio 1508

Jeremy Sprott pleaded guilty to second-degree burglary and first-degree petty theft after admitting he took and attempted to sell items from a victim’s home.
At plea, the State advised it would recommend a two-year prison term for burglary.
Defense emphasized Sprott had no prior felony convictions, had not served prison time, cooperated with police, the stolen items were recovered, and he needed substance-abuse and mental-health treatment.
Sentencing court reviewed the PSI, heard statements, found recidivism likely, referenced prior juvenile burglary, and noted the lasting harm burglary causes victims.
The court imposed a two-year prison term for burglary (no jail for petty theft); Sprott appealed, arguing the court failed to properly consider R.C. 2929.12 factors and should have imposed community control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by imposing a two-year prison term instead of community control by failing to consider or weigh R.C. 2929.12 factors	State: court properly considered PSI, statements, and sentencing principles and may exercise discretion to impose prison when recidivism likely	Sprott: court ignored/failed to give adequate weight to R.C. 2929.12 factors that made the offense less serious and supported community control (no felony record, no physical injury, cooperation, recovered property, need for treatment)	Affirmed: appellate court held defendant did not show the trial court failed to consider the statutory factors or that the sentence was contrary to law or strikingly inconsistent with R.C. 2929.12; trial court discretion upheld

State v. Marcum, 146 Ohio St.3d 516 (2016) (appellate-review standard for felony sentences under R.C. 2953.08(G)(2))
State v. Foster, 109 Ohio St.3d 1 (2006) (R.C. 2929.12 does not require judicial fact-finding or specific findings at sentencing)
State v. Holin, 174 Ohio App.3d 1 (2007) (trial court not required to give particular weight to any sentencing factor; sentencing discretion)