State v. Wells, 2017 Ohio 8738

William Wells was sentenced to four consecutive 12‑month prison terms (aggregate 48 months) across three Cuyahoga County case numbers.
Trial court’s journal entry included the R.C. 2929.14(C)(4) findings supporting consecutive sentences, but the court did not state those findings on the record at the sentencing hearing.
The State conceded the trial court erred by failing to make the statutory findings on the record and asked for remand for resentencing with proper on‑the‑record findings.
Wells asked the appellate court to modify the sentence to concurrent terms under R.C. 2953.08(G)(2)(a), arguing the record did not support consecutive sentences.
The primary legal question was whether consecutive sentences could stand where the required statutory findings were recorded in the journal entry but not made orally at the sentencing hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences are lawful when the trial court failed to state R.C. 2929.14(C)(4) findings on the record at sentencing	State concedes error and asks remand for resentencing so the court can make required on‑the‑record findings	Wells asks modification to concurrent sentences under R.C. 2953.08(G)(2)(a), asserting record does not support consecutive terms	Reversed and remanded: sentence vacated because required findings were not made on the record; trial court must consider consecutive terms and, if imposed, state findings on the record and include them in the journal entry

State v. Bonnell, 140 Ohio St.3d 209, 2014-Ohio-3177, 16 N.E.3d 659 (trial court must both state R.C. 2929.14(C)(4) findings at sentencing and incorporate them in the journal entry)