State v. Wells, 2012 Ohio 5529

State charged Wells in Champaign County with drug offenses; Wells pled guilty to two charges and two were dismissed.
Offenses pled to: Possession of Cocaine (second-degree felony) and Aggravated Possession of Drugs (fifth-degree).
Trial court sentenced Possession of Cocaine to 3 years and Aggravated Possession of Drugs to 12 months, to be served consecutively for a total of 4 years.
Wells appealed contending the court imposed consecutive sentences without proper findings or reasons.
The trial court made on-record findings that consecutive sentences were necessary to protect the public and punish Wells and that they were not disproportionate; these were repeated in the judgment entry.
The Intermediate Court of Appeals affirmed, concluding early no additional reasons were required once statutory findings were made.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by imposing consecutive sentences without required findings or reasons	Wells argues no requisite findings or reasons were made.	Wells contends lack of proper findings/reasons invalidates consecutive sentences.	Findings satisfied; no mandatory articulation of reasons required.

State v. Alexander, 2012-Ohio-3349 (1st Dist. Hamilton Nos. C-110828 and C-110829, 2012-Ohio-3349) (consecutive-sentence findings differ from former requirements; findings suffice)
State v. Comer, 793 N.E.2d 473 (Ohio Sup. Ct., 2003) (duties to articulate reasons for consecutive sentences evolved)
State v. Hodge, 941 N.E.2d 768 (128 Ohio St.3d 1, 2010-Ohio-6320) (pre-HB 86 rule; no obligation to engage judicial fact-finding absent statute)
State v. Wagner, 2012-Ohio-2791 (2d Dist. Clark No. 2011 CA 27, 2012-Ohio-2791) (post-HB 86; no requirement to give reasons if statutory findings are made)
State v. Blackwell, 2021-Ohio-3253 (8th Dist. Cuyahoga No. 97507, 2021-Ohio-3253) (notes added requirement to make specific R.C. 2929.14(C)(4) findings)