State v. Taylor, 2017 Ohio 1405

Christopher G. Taylor was indicted on abduction (felony 3), domestic violence (felony 3), and obstructing official business (misdemeanor 2) for an incident in which he struck and restrained his wife in the family home while children were present; he refused police orders at the scene.
Pursuant to a plea agreement, Taylor pled guilty to one count of domestic violence (third-degree felony); remaining counts were dismissed.
The court ordered a presentence investigation. At sentencing, defense asked for community-based sanctions (CCC) and treatment for substance abuse; victim and family urged leniency.
The trial court sentenced Taylor to 18 months' imprisonment (with 92 days credit) and imposed mandatory postrelease control, concluding he was not amenable to community control.
Taylor appealed, arguing the 18-month prison term violated the purposes and principles of felony sentencing and that the court should have used the least restrictive sanctions (CCC).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 18‑month prison sentence violated R.C. 2929.11/2929.12 (felony sentencing principles)	State: Sentence is within statutory range, court considered statutes and factors, and record supports finding community control was inappropriate	Taylor: Court failed to use minimum sanctions and should have imposed community-based correctional placement	Court affirmed: sentence is within range, court considered 2929.11/2929.12 in its entry, and record supports the sentence; not clearly and convincingly contrary to law

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (sets standard for appellate review of felony sentences under R.C. 2953.08(G)(2))
State v. Brandenburg, 146 Ohio St.3d 221 (Ohio 2016) (clarifies appellate power to modify or vacate sentences only when clearly and convincingly contrary to law)