State v. Williams, 2014 Ohio 3624

On August 9, 2012 police observed Lamont Williams and a co-defendant shooting at houses; spent casings, bullet holes, and a 9mm recovered; Williams’ fingerprints were on the gun; women and small children were present.
Williams was indicted on multiple counts (seven felonious-assault counts and seven counts of improperly discharging a firearm into a habitation) with firearm specifications.
In February 2013 Williams pled no contest to Count 1 (felonious assault, R.C. 2903.11(A)(2)), and Counts 2–14 and all firearm specifications were dismissed.
The trial court reviewed a PSI, recited the facts, and found Williams had an extensive juvenile and adult record of misdemeanors and prior felony conduct.
The court sentenced Williams to seven years’ imprisonment (within the statutory range for a second-degree felony) and imposed three years of mandatory postrelease control.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the seven-year sentence is contrary to law because outside statutory range	State: sentence is within statutory range for second-degree felonies (2–8 years)	Williams: trial court abused its discretion imposing seven years	Held: Sentence is within statutory range; not contrary to law
Whether sentence is contrary to law for failing to consider R.C. 2929.11/2929.12 factors	State: trial court stated it considered statutory sentencing principles and factors	Williams: argued trial court abused discretion / failed to properly consider factors	Held: Court adequately indicated it considered R.C. 2929.11 and 2929.12; need not recite each factor; sentence not clearly and convincingly contrary to law

State v. Kalish, 120 Ohio St.3d 23 (2008) (established analytic framework for appellate review of felony sentences and standards for determining whether a sentence is lawful)