State v. Volz, 2022 Ohio 4134

Derrick Volz was convicted in four separate matters (three Clermont County cases and one Warren County case).
He had prior community-control sanctions in the Clermont cases; committing the Warren County offense violated those sanctions and led to revocations.
The trial court imposed a 180-day concurrent jail term for a misdemeanor and four 9-month prison terms for felony drug offenses.
The court ordered the four 9-month terms to run consecutively to each other and consecutively to the Warren County prison term.
At the sentencing hearing the court articulated findings that consecutive sentences were necessary to protect the public and to punish Volz and referenced his criminal history and separate harms, but it did not expressly state the statutory proportionality finding required by R.C. 2929.14(C)(4).
The sentencing entry, however, included all the R.C. 2929.14(C)(4) findings; Volz appealed the consecutive-sentence orders.

Issue	State's Argument	Volz's Argument	Held
Whether the trial court complied with R.C. 2929.14(C)(4) by making all required findings at the sentencing hearing before imposing consecutive sentences	The required proportionality finding can be inferred from the court's oral statements about criminal history, separate harms, and the need to punish and protect the public	The court failed to orally make the R.C. 2929.14(C)(4) proportionality finding at the sentencing hearing, so consecutive sentences are contrary to law	The court vacated the consecutive-sentence component because the trial court did not make the proportionality finding on the record at the sentencing hearing and remanded for resentencing on consecutive terms

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (describing the standard of review for felony sentences under R.C. 2953.08(G)(2))
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (holding trial courts must state R.C. 2929.14(C)(4) findings at the sentencing hearing and incorporate them into the record)