State v. Williams, 2017 Ohio 7461

Marcell Williams pleaded guilty to two counts of felonious assault (each with a firearm specification) and one count of having weapons while under disability.
Trial court sentenced Williams to three years on each felonious assault count and three years on each firearm specification, ordering those terms consecutive to each other.
The three-year sentence for having weapons while under disability was ordered concurrent to the others, producing a total aggregate term of 12 years.
The sentencing entry included reasons for consecutive sentences, but the trial court did not state the required statutory findings on the record at the sentencing hearing.
The State conceded the court failed to make the required on-the-record findings under R.C. 2929.14(C)(4).
The Ninth District Court of Appeals reversed and remanded for resentencing, concluding the sentence was contrary to law because the required findings were not made on the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the statutory on-the-record findings required to impose consecutive sentences under R.C. 2929.14(C)(4)	Williams: Court failed to state required findings on the record before imposing consecutive sentences	State: (implicitly) sentencing entry contained reasons; but concession that on-the-record findings were not made	Court: Reversed — clear and convincing evidence shows required findings were not made on the record; sentence contrary to law; remand for resentencing

Bonnell v. Ohio, 140 Ohio St.3d 209 (requires trial court to make statutory findings and state them at sentencing under Crim.R. 32)
Marcum v. Ohio, 146 Ohio St.3d 516 (standards for appellate review of felony sentences; modification/vacatur only on clear and convincing evidence)
Cross v. Ledford, 161 Ohio St. 469 (definition of clear and convincing evidence)