State v. Steiner, 2016 Ohio 4648

In May 2015 Timothy D. Steiner (age 37) began sending sexually explicit messages to a nine‑year‑old girl via Facebook and text after meeting her at a slumber party.
An ICFR detective assumed the child’s identity and continued communications; over ~10–14 days Steiner sent hundreds of increasingly graphic messages, solicited photos, and arranged a May 22 meeting with detailed instructions.
Police staged a sting at a vacant house; Steiner approached the window and was arrested before any contact with the child occurred.
Indictment: Attempted rape (first‑degree felony after amendment) and four counts of importuning (third‑degree felonies); burglary count dismissed.
Steiner pled guilty to attempted rape and the four importuning counts under a plea agreement; sentencing: 9 years (attempted rape) + 24 months on each importuning count, ordered consecutively for a total of 17 years.
On appeal Steiner challenged imposition of consecutive sentences; the majority affirmed, finding the record supported the R.C. 2929.14(C)(4) findings, while one judge dissented, arguing subsections (b) and (c) were not supported by the record.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Steiner)	Held
Whether the trial court properly imposed consecutive sentences under R.C. 2929.14(C)(4)	The court made the statutory findings at sentencing (necessity to protect/punish; not disproportionate) and expressly found (b) multiple offenses as part of a course of conduct producing harm so great/unusual that separate terms are warranted and (c) recidivism risk.	Steiner argued the consecutive sentence findings, particularly (b) and (c), lack record support: the charged offenses were directed to an undercover officer (not the child), the child did not suffer the alleged harm from the charged offenses, and his prior record was one misdemeanor unrelated to sex.	Majority: Affirmed. The record shows the court engaged in the correct analysis and made the required findings at the hearing; evidence (grooming over days, multiple offenses, victim age/psychological harm, prior record) supports conclusions. Dissent: Would reverse as (b) and (c) are unsupported.

State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court must make R.C. 2929.14(C)(4) findings at sentencing and incorporate them into the entry, but need not recite statutory language or state reasons)
State v. Kalish, 120 Ohio St.3d 23 (2008) (previous Ohio sentencing-review framework discussed)
Cross v. Ledford, 161 Ohio St. 469 (1954) (definition and standard for clear and convincing evidence)