State v. Webster, 2017 Ohio 932

Defendant Marcellus Webster pled guilty to involuntary manslaughter, aggravated robbery with a 3-year firearm specification, and grand theft pursuant to a plea agreement.
Plea agreement set a joint recommended sentencing range: minimum 10 years to maximum 20 years, specified offenses would not merge and parties stipulated to agreed consecutive-sentencing findings.
At plea hearing the court and defense counsel acknowledged the agreed consecutive terms and the court stated the agreement removed its obligation to recite consecutive-sentence findings on the record.
Sentencing: 11 years (involuntary manslaughter), 3 years (aggravated robbery) consecutive to a 3-year firearm specification, and 6 months (grand theft); total effective sentence 14.5 years, ordered consecutive to prior cases.
Webster appealed, arguing the trial court failed to consider his youth under R.C. 2929.11/2929.12 and failed to make required consecutive-sentencing findings under R.C. 2929.14(C)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate review is barred where defendant and prosecution jointly recommend a sentence	State: Jointly recommended sentence that complies with mandatory provisions is not reviewable under R.C. 2953.08(D)(1)	Webster: Trial court failed to consider youth and failed to make statutory consecutive-sentence findings	Court: Appeal barred by R.C. 2953.08(D)(1); sentence "authorized by law" so errors-in-exercise-of-discretion claims not reviewable

State v. Underwood, 922 N.E.2d 923 (Ohio 2010) (a sentence is "authorized by law" for purposes of R.C. 2953.08(D)(1) only if it comports with all mandatory sentencing provisions)