State v. Squires, 2019 Ohio 4676

Defendant Jeffrey Squires was indicted on 12 counts arising from sexual assaults of an adult woman with Down syndrome who lived with his girlfriend; under a plea deal he pled guilty to three counts of sexual battery (third-degree felonies).
The charges corresponded to three separate incidents occurring in different rooms of the residence; the remaining counts were dismissed.
At sentencing the court imposed 48 months on each count to run consecutively, totaling 12 years, after victim and family impact statements and investigative testimony describing the victim’s developmental limitations.
At the sentencing hearing the court stated on the record that consecutive sentences were "necessary to protect the public and punish the offender," were "not disproportionate," and that "the harm is so great or unusual that a single term does not adequately reflect the seriousness of the defendant's conduct."
The written sentencing entry repeated those findings but did not expressly state that at least two offenses were committed as part of one or more courses of conduct (the first clause of R.C. 2929.14(C)(4)(b)).
The Eighth District vacated the consecutive-sentence component and remanded for resentencing because the record and entry failed to make all required R.C. 2929.14(C)(4) findings as interpreted in Bonnell.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the required R.C. 2929.14(C)(4) findings at the hearing and in the journal entry to impose consecutive sentences	Court made required findings on necessity, proportionality, and harm; sentences are within statutory ranges and parties acknowledged separate incidents	Trial court failed to make all statutory findings on the record and in the entry (particularly the course-of-conduct element) and state did not adequately distinguish separate acts	Vacated consecutive sentences and remanded for resentencing; court found the record lacked the required finding that at least two offenses were part of a course of conduct even though other findings were stated
Whether the individual terms or overall sentence were otherwise contrary to law because they fell outside statutory range	Individual terms were within statutory sentencing ranges and presumptively valid	Consecutive imposition is contrary to law without statutory findings despite individual terms being lawful	Individual 48‑month terms are within range, but the consecutive imposition was vacated under R.C. 2953.08(G)(2) because the required findings were not supported or properly incorporated into the entry

State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make required consecutive-sentence findings on the record and incorporate them in the journal entry; no talismanic phrasing required but findings must be discernible)
State v. Beasley, 153 Ohio St.3d 497 (Ohio 2018) (three statutory findings required to overcome presumption in favor of concurrent sentences)
State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (appellate review standard under R.C. 2953.08(G)(2) for felony sentences)
State v. Sapp, 105 Ohio St.3d 104 (Ohio 2004) (to find offenses part of a course of conduct, court must discern a connection, common scheme, pattern, or psychological thread)
State v. Short, 129 Ohio St.3d 360 (Ohio 2011) (course-of-conduct may be established by factual links such as time, location, weapon, or similar motivation)