State v. Tackett, 2019 Ohio 4960

Natasha Tackett was indicted separately for fifth-degree felony breaking-and-entering (R.C. 2911.13(A)) and fifth-degree felony drug trafficking (R.C. 2925.03(A)(2)).
She entered guilty pleas to both counts pursuant to plea negotiations that included a joint sentencing recommendation (12 months for trafficking; 5 years community control for breaking-and-entering to follow prison).
At sentencing the court reported a positive drug screen (results not in record), but ultimately imposed two 12-month prison terms and ordered them to run consecutively (total 24 months).
Tackett appealed, arguing the trial court failed to make the statutory findings required by R.C. 2929.14(C)(4) at the hearing and failed to properly incorporate those findings into the sentencing entries.
The appellate court found the trial court did not (1) state that consecutive sentences were "not disproportionate" to the offense/danger posed nor that they were necessary "to protect the public from future crime," (2) lacked support for finding the two offenses were part of a single "course of conduct," and (3) failed to incorporate specific R.C. 2929.14(C)(4) findings into the entries.
Result: The Fourth District vacated the sentences and remanded for resentencing.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Tackett)	Held
Whether the trial court complied with R.C. 2929.14(C)(4) when imposing consecutive sentences	The trial court made all required C(4) findings at the hearing and properly incorporated them into the sentencing entries	The court failed to make required findings on the record (no explicit non-disproportionality finding; no explicit finding that consecutive terms are necessary to protect the public from future crime) and did not incorporate specific findings into the entries	Held for Tackett: court failed to make required C(4) findings at the hearing and failed to incorporate them into the entries; remanded for resentencing
Whether the record supports the trial court's "course of conduct" finding under C(4)(b)	The offenses were suitable for consecutive terms under the court's findings	The two offenses occurred on different dates and the record contains no evidence they were related or part of a single course of conduct	Held for Tackett: no record support that offenses were part of a course of conduct; that finding was unsupported

State v. Bonnell, 140 Ohio St.3d 209, 16 N.E.3d 659 (Ohio 2014) (trial court must make R.C. 2929.14(C)(4) findings at sentencing hearing and incorporate them into the sentencing entry)