State v. Williams, 2019 Ohio 5296

Consolidated appeal of three Seneca C.P. cases (17-CR-0033, 18-CR-0021, 18-CR-0178) involving multiple trafficking-in-cocaine counts and one count of possessing criminal tools.
In 17-CR-0033 and 18-CR-0021 Williams pleaded guilty pursuant to joint recommendations of community control with reserved consecutive prison terms if community control was violated.
Williams absconded from supervision, was apprehended, and state filed community-control violation notices alleging further cocaine sales.
Revocation hearings (for the two plea cases) resulted in imposition of the reserved prison terms (12 months per count, ordered consecutive across and among cases).
In 18-CR-0178 Williams proceeded to bench trial after counsel substituted; on first day of trial he requested a continuance for newly discovered evidence, the trial court denied it, and the court convicted him on all counts and imposed consecutive sentences totaling 84 months, consecutive to the other cases.
Williams appealed, arguing (1) the trial court abused its discretion by denying the continuance in 18-CR-0178, and (2) the consecutive sentences were disproportionate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court abuse its discretion by denying Williams' last‑minute motion for a continuance in 18‑CR‑0178?	State: Denial proper because case had lengthy history of continuances, defendant gave no timeline, and defense failed to proffer or describe the alleged newly discovered evidence.	Williams: Counsel needed time to review and decide whether to proffer newly discovered evidence; denial deprived him of opportunity to preserve evidence.	Court: No abuse of discretion; multiple prior continuances and no proffer made the request unreasonable, so denial affirmed.
Were consecutive sentences disproportionate and therefore unlawful?	State: Sentences lawful; two plea cases included jointly recommended consecutive terms (not reviewable under R.C. 2953.08(D)(1)); trial court made required findings for consecutive terms in 18‑CR‑0178 given defendant’s history and community‑control status.	Williams: Consecutive terms disproportionate because cocaine amounts were small and not unusually serious.	Court: Consecutive sentences affirmed. Agreed consecutive terms in the plea cases are not reviewable; for 18‑CR‑0178 the court made required findings and relied on defendant’s extensive drug history, commission while under community control, failures at treatment/supervision, and other recidivism factors.

State v. Unger, 67 Ohio St.2d 65 (1981) (lists factors trial courts should weigh when ruling on motions for continuance)