State v, Watkins, 2022 Ohio 1231

Dazshea Watkins was indicted on 32 counts after attempting to drown and smother her then‑5‑year‑old son; she videotaped the act and sent it to the child’s father.
Multiple competency and sanity evaluations (Drs. Hernandez, Gordon, Magalotti, Wood) concluded Watkins was competent to stand trial and sane at the time of the offense.
Watkins pled guilty pursuant to a negotiated plea to seven counts (including attempted murder, kidnapping, felonious assault, endangering children, pandering obscenity of a minor) and acknowledged Tier 2 registration and Reagan Tokes exposure for certain felonies.
At sentencing the court viewed the video, heard victim‑impact and mitigation, sentenced on the counts to combined consecutive and concurrent terms, and applied Reagan Tokes to the attempted murder term; aggregate minimum 14 years, maximum 16.5 years.
Watkins appealed arguing (1) the trial court failed to make the statutory findings required for consecutive sentences and failed to incorporate them into the journal entry, and (2) the Reagan Tokes indefinite sentence is unconstitutional.
The court affirmed the sentence, remanded for the trial court to issue a nunc pro tunc entry to include the consecutive‑sentence findings made at the hearing, and rejected the constitutional challenge under controlling precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made required R.C. 2929.14(C)(4) findings before imposing consecutive sentences	State: Trial court made the necessary findings at the sentencing hearing (protection/punishment, proportionality, statutory basis)	Watkins: Court failed to make the required findings and failed to incorporate them into the journal entry	Court: Findings were made on the record; overrules claim but remands for nunc pro tunc to incorporate findings into the sentencing entry
Whether the Reagan Tokes indefinite sentence is unconstitutional (separation of powers / due process)	State: Reagan Tokes is constitutional and properly applied to the attempted murder term	Watkins: Indefinite sentence violates separation of powers and due process under U.S. and Ohio Constitutions	Court: Rejects constitutional challenge based on controlling authority; overrules claim

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (sets standard for appellate review of felony sentences under R.C. 2953.08(G)(2))
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make statutory consecutive‑sentence findings on the record; journal omission can be corrected by nunc pro tunc)
State v. Edmonson, 715 N.E.2d 131 (Ohio 1999) (trial court must note that it engaged in the required sentencing analysis and specify the bases supporting its decision)