State v. West, 2018 Ohio 956

Melvin West pleaded guilty to two trafficking counts (one fifth-degree with forfeiture for heroin; one fourth-degree with juvenile specification for cocaine) as part of a plea agreement dismissing other charges.
West failed to appear for initial sentencing; later surrendered and was resentenced on July 11, 2016.
Trial court imposed maximum terms: 12 months (heroin) and 18 months (cocaine), ordered to run consecutively; also advised of license suspension and potential postrelease control.
Sentencing court referenced West’s ~30-year criminal history, long-time drug dealing, addictions, and the local heroin epidemic when explaining its findings.
The journal entry stated the court considered statutory sentencing factors and included the R.C. 2929.14(C)(4) findings; the entry also imposed court costs though costs were not orally announced at sentencing.
West appealed, challenging (1) the legality/support for the maximum and consecutive sentences, and (2) imposition of court costs without oral notification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality/support for maximum sentence	State: sentence within statutory range and court considered 2929.11/2929.12 factors	West: maximum not supported by record; court failed to justify maximum	Court: affirmed — trial court may impose maximum within statutory range; consideration of sentencing factors is presumed and record supports sentence
Legality/support for consecutive sentences	State: court made required R.C. 2929.14(C)(4) findings and supported them with defendant's record and conduct	West: court failed to make proper findings or explain how consecutive terms protect public; findings unsupported by record	Court: affirmed — court made the three-tier 2929.14(C)(4) findings (necessity, proportionality, and one statutory predicate) and record supports them
Imposition of court costs without oral notification	State: originally conceded error but argued remand appropriate; later relied on intervening authority	West: court costs ordered in journal but not imposed orally; requests remand to waive costs due to indigency	Court: affirmed — after State v. Beasley and statutory amendment, oral announcement at sentencing is not prerequisite to enforce costs; no remand required

State v. Marcum, 146 Ohio St.3d 516 (2016) (appellate review standard for sentences; may vacate only if sentence is clearly and convincingly contrary to law)
State v. Bonnell, 140 Ohio St.3d 209 (2014) (trial court need not use rote statutory language for consecutive-sentence findings; record must permit review)
State v. Joseph, 125 Ohio St.3d 76 (2010) (trial courts must orally notify defendants of court costs at sentencing)
State v. Foster, 109 Ohio St.3d 1 (2006) (trial courts have discretion to impose maximum sentence within statutory range)