State v. Townsend, 2014 Ohio 924

Townsend lived with his girlfriend Dixon; Dixon also rented a room to Doss and on Sept. 18, 2011 Townsend assaulted Doss with a hammer, causing head injuries.
Townsend was indicted on two counts of felonious assault; he initially pleaded not guilty and was deemed competent to stand trial.
Townsend retracted his pleas and, as part of a plea agreement, pled guilty to one count of aggravated assault (R.C. 2903.12(A)(2)); the court accepted the plea and scheduled sentencing.
At sentencing, testimony was heard from Doss, Dixon, and Townsend; the court noted Townsend’s lengthy criminal history and imposed an 18-month prison sentence with postrelease control warning.
Townsend appeals challenging the maximum 18-month sentence as unlawful; the State argues the sentence complies with statutory guidelines and sentencing purposes, and the court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 18-month sentence is clearly and convincingly contrary to law	Townsend	State	Not contrary to law; affirmed

State v. Venes, 2013-Ohio-1891 (8th Dist. 2013) ( appellate review of maximum sentence under R.C. 2953.08(G)(2) )
State v. Calliens, 2012-Ohio-703 (8th Dist. 2012) (no required findings under 2929.11/2929.12 for maximum sentence)
State v. Corbett, 2013-Ohio-4478 (8th Dist. 2013) (statutory compliance may be shown without specific 2929.11/2929.12 findings)
State v. Kalish, 120 Ohio St.3d 23 (2008-Ohio-4912) (comparing sentencing findings with statutory requirements)
State v. Arnett, 88 Ohio St.3d 208 (2000-Ohio-302) (setting standard for felony sentencing and consideration of 2929.11/2929.12)