State v. Wright
2013 Ohio 3132
Ohio Ct. App.2013Background
- Ellery Wright pled guilty to two separate fifth-degree felonies: drug possession (May 8, 2012) and theft (June 5, 2012).
- Initial sentences: drug possession — 12 months community control, GED and treatment requirements; theft — 18 months community control and $3,500 restitution.
- Wright violated community control by testing positive for PCP and cocaine, failing to attend ordered drug treatment and AA meetings, and not pursuing his GED.
- At a violation hearing (Aug. 10, 2012) the trial court revoked community control and imposed the maximum 12-month prison term on each case, to be served consecutively.
- Wright appealed, arguing the trial court erred by imposing maximum consecutive sentences without meaningful analysis supporting the statutory findings required for consecutive terms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly imposed maximum consecutive sentences under R.C. 2929.14(C)(4) | State: trial court made the required statutory findings (necessary to protect public/punish; not disproportionate; statutory factor present) | Wright: court failed to provide meaningful analysis or reasons supporting those findings | Court affirmed: record shows the court made the required findings and need not provide extended justification; consecutive maximum sentences were proper |
Key Cases Cited
- None with official reporter citations were relied on in the opinion (the court cited recent Ohio appellate decisions and statutory provisions but not authorities having official reporter citations).