State v. White, 2013 Ohio 3808

White pleaded guilty to amended counts of attempted felonious assault and having weapons while under disability under a plea agreement.
At sentencing, the court imposed consecutive terms of 24 months and 12 months, but the journal entry stated a single 24-month term.
This court remanded to issue a final order conforming to case law requiring a sentence on each count.
On remand, the trial court issued nunc pro tunc entries sentencing White to two years for attempted felonious assault and one year for having weapons under disability, consecutive.
The issues concern (i) improper consecutive-sentence findings under HB 86/R.C. 2929.14(C)(4), (ii) postrelease-control advisement, and (iii) imposition of court costs without open-court notice.
The appellate court reverses for limited remands to correct findings, advise on postrelease control, and delete court costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consecutive-sentence findings missing	White and state agree findings were required but absent.	White argues lack of findings requires correction/remand.	Consecutive sentences require HB 86 findings; remanded for proper findings.
Postrelease control advisement	Postrelease-control advisement was improper or incomplete.	White requests de novo sentencing or proper advisement.	Error in informing postrelease control; remanded for limited postrelease-control hearing with proper advisement.
Court costs not properly ordered	Costs not properly imposed without open-court notice.	N/A	Imposition of court costs sustained as error; remand to delete costs from entry.

State v. Jones, 2013-Ohio-489 (8th Dist. Cuyahoga No. 98371) (reinstates HB 86 findings requirement for consecutive sentences)
State v. Wright, 2013-Ohio-3132 (8th Dist. Cuyahoga No. 98901) (guides HB 86 findings and proportionality review)
State v. Venes, 2013-Ohio-1891 (8th Dist. Cuyahoga No. 98682) (consecutive-sentence framework under HB 86)
State v. Dodson, 2013-Ohio-1344 (8th Dist. Cuyahoga No. 98521) (limited remand for proper consecutive-sentence entry)
State v. Ross, 2013-Ohio-3130 (8th Dist. Cuyahoga No. 98763) (limited remand approach for HB 86 findings)
State v. Walker, 2012-Ohio-4274 (8th Dist. Cuyahoga No. 97648) (remand procedure for proper findings on consecutive sentences)
State v. Fischer, 128 Ohio St.3d 92 (2010-Ohio-6238) (void postrelease control when not properly imposed; remedial options)
State v. Freeman, 2013-Ohio-3004 (8th Dist. Cuyahoga No. 99351) (addressing postrelease-control notification remedies)
State v. Harris, 2011-Ohio-6762 (8th Dist. Cuyahoga No. 96887) (postrelease-control advisement remedy considerations)
State v. Joseph, 2010-Ohio-954 (125 Ohio St.3d 76) (court costs must be announced in open court but do not void sentence)
State v. Shaffer, 2011-Ohio-844 (8th Dist. Cuyahoga Nos. 95273 and 95274) (remedies for improper court-cost imposition)