State v. Woofter, 2019 Ohio 1166

Brian K. Woofter pled guilty to multiple fifth-degree felonies across three Portage County cases (Theft in 2015 CR 00552; seven counts of Receiving Stolen Property in 2017 CR 00907 and 2017 CR 01111).
He originally received community-control/intensive-supervision terms in each case; probation violation motions were later filed.
At a June 18, 2018 hearing Woofter admitted violating probation; the trial court revoked community control and imposed prison terms.
In 2017 CR 00907 the court imposed six 12-month terms, ordering five consecutive and one concurrent; the other two cases received 12-month sentences to run concurrently.
The written judgment (June 20, 2018) memorialized those sentences; Woofter appealed, arguing the trial court failed to make the statutory findings required to impose consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court made the statutory findings required by R.C. 2929.14(C)(4) before imposing consecutive sentences	State conceded the trial court did not make all required findings in the entry or clearly at sentencing	Woofter argued consecutive sentences were invalid because the court failed to make the required R.C. 2929.14(C)(4) findings at the hearing and in the judgment entry	Court held the record lacked the required findings; vacated the sentence in 2017 CR 00907 and remanded for resentencing, but affirmed concurrent sentences in the other two cases

Beasley, 153 Ohio St.3d 497 (Ohio 2018) (explains trial courts must make three distinct R.C. 2929.14(C)(4) findings to impose consecutive terms)
Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (courts must make the required statutory findings at sentencing and incorporate them in the judgment entry but need not state supporting reasons)