State v. Tea, 2016 Ohio 741

Appellant Trevor Tea pled guilty in 2009 to three counts of felony nonsupport, each a fifth-degree felony.
Tea was placed in a pretrial diversion program with dismissal pending successful completion.
In 2013 the state sought to revoke diversion; Tea consented and pleas remained; in 2014 he received community control for three years.
Judgment entry of sentence indicated 12-month prison terms on counts seven, eight, and nine, to run consecutively for a 36-month aggregate.
In 2015 Tea's probation was revoked for noncompliance; the court imposed the underlying sentence of consecutive 12-month terms.
The court stated findings supporting consecutive sentences and noted three different children were involved; Tea appeals, arguing lack of statutory compliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences complied with 2929.14(C)(4).	Tea's record lacks all required findings for consecutive terms.	Tea contends the court made necessary findings at sentencing.	Record lacks all required R.C. 2929.14(C)(4) findings; orderly resentencing required.
Whether the record shows the court considered disproportionate effect of consecutive terms.	Court did not articulate proportionality finding.	Court found multiple factors supporting consecutive sentences including three offenses and course of conduct.	Judgment entry omission of the proportionality finding renders the sentence unlawful; remand for resentencing.

State v. Bonnell, 140 Ohio St.3d 209 (2014-Ohio-3177) (trial court must make 2929.14(C)(4) findings and incorporate them; not required to recite statute word-for-word)
State v. Banks, 2014-Ohio-1000 (6th Dist. Lucas No L-13-1095) (appellate review of consecutive-sentence decisions under 2953.08(G)(2))
State v. Steck, 2014-Ohio-3623 (6th Dist. Wood Nos. WD-13-017 and WD-13-018) (consecutive sentences following community-control revocation reviewed under 2953.08)