State v. Watson

Citations

• 2026 Ohio 831

Syllabus

Crim.R. 43(A)(1); consecutive sentences; R.C. 2929.41; R.C. 2929.14; courses of conduct. Appellant contested term of imprisonment arising from guilty plea. Case remanded for resentencing where court failed to sentence appellant for one of the charged offenses at hearing, attempting to do so only in a subsequent sentencing entry, in violation of Crim.R. 43(A)(1). Court also erred in announcing at hearing that it was running all prison terms consecutively, violating R.C. 2929.41 where appellant's convictions included both felonies and misdemeanors. Court also failed to make a complete \courses of conduct\ finding at hearing under R.C. 2929.14(C)(4)(b) to support its imposition of consecutive sentences. On remand, court instructed to make consecutive-sentencing findings in accordance with R.C. 2929.41 and 2929.14, as merited by the record.