State v. Washington
Annotate this CaseDefendant was convicted of failure to comply with a police officer and obstruction of official business. The trial court imposed separate sentences for the two offenses. Defendant appealed, arguing that the offenses should have merged at sentencing as allied offenses of similar import under Ohio Rev. Code 2941.25. The appellate court remanded for a determination as to whether the offenses were allied offenses under State v. Johnson, which instructs courts that a defendant's conduct "must be considered" when determining whether multiple offenses merge at sentencing pursuant to section 2941.25. The trial court determined that the offenses were not allied offenses of similar import and imposed separate prison terms for the two offenses. The court of appeals reversed, concluding that Defendant's sentences merged under Johnson because they were based on the same conduct. The Supreme Court reversed, holding (1) when deciding whether to merge multiple offenses at sentencing pursuant to section 2941.25, a court must review the entire record to determine whether the offenses were committed separately or with a separate animus; and (2) the court of appeals erred by relying on Johnson for the proposition that a court may consider a defendant's conduct only as it was described by the state's theory at trial.
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