State v. Bonnell

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At issue in this appeal was whether a trial court must engage in judicial fact-finding prior to imposing consecutive sentences on an offender. In this case, Appellant was sentenced to consecutive sentences aggregating eight years and five months for convictions arising out of four instances in which Appellant took $117 in change from vending machines. On appeal, Appellant argued that the imposition of consecutive sentences was contrary to law because the trial court did not expressly make the findings mandated by Ohio Rev. Code 2929.14(C)(4) and did not provide reasons in support of those findings when imposing consecutive sentences. The Supreme Court vacated the sentence and remanded for resentencing, holding (1) a trial court is required to make the findings required by section 2929.14(C)(4) at the sentencing hearing and incorporate its findings into its sentencing entry, but the court has no obligation to state reasons to support its findings; and (2) the trial court in this case did not make all of the findings required by section 2929.14(C)(4) at the time it imposed consecutive sentences, and neither did it incorporate all of the necessary findings into its judgment entry. Remanded for resentencing. View "State v. Bonnell" on Justia Law