State v. Wati, 2019 Ohio 4827

In Nov. 2018 Wati was indicted on two counts of rape and two counts of sexual battery arising from a Sept. 23, 2017 sexual assault (fellatio and vaginal intercourse) of a single victim.
In Jan. 2019 Wati pled guilty to two counts of sexual battery; the state dismissed the rape counts.
The trial court sentenced Wati to 48 months on each sexual-battery count to run consecutively, for an aggregate 96-month prison term.
At sentencing the court made oral findings that consecutive sentences were necessary to protect the public and not disproportionate, described the assaults as forcible, and (partially inaudible) stated the harm was so great that a single term was inadequate.
The sentencing entry explicitly incorporated R.C. 2929.14(C)(4)(b) language finding the offenses were part of one or more courses of conduct and the harm was so great and unusual that consecutive terms were warranted.
Wati appealed, arguing the record did not support a "course of conduct" finding and the trial court failed to announce that basis at sentencing; the majority affirmed, a judge dissented and would remand for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences were permissible under R.C. 2929.14(C)(4)(b) because the offenses were part of a "course of conduct" and the harm was so great that consecutive terms were required	State: The court engaged in the required analysis; convictions for two distinct sexual-battery acts (fellatio and vaginal intercourse) support a course-of-conduct finding; the sentencing entry contains statutory findings	Wati: The acts were part of a single, temporally unified assault against one victim and thus not a "course of conduct"; the trial court did not plainly announce a course-of-conduct finding at sentencing and the journal entry cannot cure defective oral notice	Court: Affirmed — record supports that two distinct sexual-battery convictions constituted a course of conduct, the court engaged in the required R.C. 2929.14(C)(4) analysis, and the sentencing entry properly incorporates the findings; consecutive 48-month terms upheld (dissent would remand for resentencing)

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (clarifies appellate standard of review for felony sentences under R.C. 2953.08(G)(2)).
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court need not recite statute verbatim but record must show required consecutive-sentence analysis and findings; findings must be journalized).
Knapp v. Edwards Laboratories, 400 N.E.2d 384 (Ohio 1980) (presumption of regularity when transcripts are incomplete).