State v. Timothy, 2013 Ohio 579

Timothy was indicted for escape, a second-degree felony, while on postrelease control for three prior cases.
He pled guilty to an amended fourth-degree felony escape on February 23, 2012.
Sentencing was set for March 30, 2012, but Timothy failed to appear; a capias was issued and he was later apprehended.
At sentencing on April 11, 2012, the court imposed an 18-month prison term for escape, terminated PRC on the prior cases, and ordered 15 months for PRC violations, running consecutively for a 33-month aggregate term.
Timothy timely appealed challenging the lack of proper findings for consecutive sentencing.
The appellate court held the trial court made the required statutory findings and did not abuse discretion in imposing consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consecutive-sentence findings required	Timothy argues the court failed to make the statutorily required findings for consecutive sentences.	State contends the court made the necessary findings and properly sentenced concurrently where appropriate.	Findings were made; no abuse of discretion established.

State v. Kalish, 120 Ohio St.3d 23 (2008-Ohio-4912) (two-step review for felony sentences; require statutory findings for consecutives)
State v. Bonner, 8th Dist. No. 97747 (2012-Ohio-2931) (HB 86 revived consecutive-sentence findings under R.C. 2929.14(C)(4))
State v. Matthews, 8th Dist. No. 97916 (2012-Ohio-5174) (criteria for consecutive sentences under multiple-found-offenses)
State v. Edmonson, 86 Ohio St.3d 324 (1999-Ohio-110) (statutory findings required; record must reflect analysis)
State v. Armpriester, 2008-Ohio-401 (2d Dist. No. 21930) (PRC-related consecutive-sentence rule)
State v. Doss, 2012-Ohio-5751 (8th Dist. Nos. 98228 and 98229) (no talismanic language required; must show statutory findings)