State v. Trotter, 2013 Ohio 2538

Trotter was charged in 2009 with multiple counts including rape, kidnapping, and child-pornography-related offenses; the trial began with a bench trial in 2010 which was halted when the judge suppressed computer-evidence and reversed on appeal.
After suppression was reversed, the bench trial resumed in 2011; Trotter was convicted of two counts of rape, two counts of rape under a different statutory provision, and two counts of kidnapping, with acquittals on child-pornography counts, and sentenced to 60 years.
On appeal, this court reversed in part for allied-offense error and remanded for merger and resentencing.
In 2012, at resentencing, the state elected to proceed on Counts 1 and 2 (rape) and the trial court imposed ten years on each count, running consecutively for a total of 20 years.
Trotter challenging the consecutive-sentencing order under R.C. 2929.14(C)(4) after HB 86; the court analyzed the statutory requirements.
The court ultimately held that the trial court failed to make the necessary findings on the record and remanded for resentencing with proper HB 86 findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences complied with R.C. 2929.14(C)(4) after HB 86	Trotter contends the court failed to make required HB 86 findings	State argues the record suffices to show findings	Remanded for resentencing with proper findings

State v. Bonner, 8th Dist. No. 97747, 2012-Ohio-2931 (Ohio 2012) (reinstates requirement for HB 86 findings before consecutive sentences)
State v. Dodson, 8th Dist. No. 98521, 2013-Ohio-1344 (Ohio 2013) (consecutive-sentence findings must be explicit on the record)
State v. Walker, 8th Dist. No. 97648, 2012-Ohio-4274 (Ohio 2012) (remand for proper findings under HB 86)
State v. Edmonson, 86 Ohio St.3d 324, 1999-Ohio-110 (Ohio 1999) (statutory analysis for consecutive-sentencing requirements)