State v. Palmer

Citations

• 2023 Ohio 1232

Syllabus

The trial court made the necessary consecutive-sentence findings under R.C. 2929.14(C)(4) in imposing sentences for vehicular assault and possession of cocaine, and those findings were supported by the record. The trial court erred in concluding that appellant's six-month jail sentence for operating a vehicle while under the influence (OVI), a misdemeanor, was required to be served consecutively to the prison sentence for vehicular assault imposing the misdemeanor sentence consecutively was discretionary. The trial court also erred in ordering appellant to serve his jail term prior to his prison terms and in failing to properly impose jail-time credit. Judgment affirmed in part, reversed in part, and remanded for resentencing.