State v. Adkins, 2021 Ohio 1294

Consolidated appeals from Cuyahoga C.P. sentencing of Brandon Adkins and Charles Trowbridge; both pleaded to multiple felonies with jointly recommended aggregate sentence ranges (Adkins 7–12 years; Trowbridge 20–25 years).
Both defendants had multiple firearm specifications attached to several felony counts; the trial court imposed some firearm-specification terms but declined to impose terms on several other specifications the state argued were mandatory.
The trial court found many of the charged offenses occurred in separate transactions (different dates, locations, victims) but nevertheless did not impose prison terms on all firearm specifications tied to those separate transactions.
The state appealed, arguing the court violated mandatory provisions of R.C. 2929.14(B)(1)(a), (b), (g) and 2929.14(C)(1)(a) that generally require firearm-specification terms to be imposed and served consecutively unless multiple specifications arise from the same transaction.
The appellate court reviewed whether the jointly recommended sentences were still "authorized by law" (and thus unreviewable) by determining whether the trial court complied with mandatory sentencing provisions governing firearm specifications.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to impose consecutive prison terms on all firearm specifications when the felonies were not part of the same act or transaction	The state: where firearm specs relate to separate transactions the court must impose consecutive specification terms under R.C. 2929.14(C)(1)(a) and may not limit them under (B)(1)(g)	Defendants: agreed to jointly recommended aggregate ranges; some specifications covered by R.C. 2929.14(B)(1)(g) and the court had discretion on remaining specs; some counts could be treated as same transaction	The court held the trial court erred: where firearm specs correspond to separate transactions the court must impose consecutive specification terms; judgment affirmed in part, reversed in part, and remanded to impose sentences on all applicable firearm specifications.

State v. Wills, 69 Ohio St.3d 690, 635 N.E.2d 370 (Ohio 1994) (defines "transaction" as a series of continuous acts bound by time, space, and purpose toward a single objective)
State v. Underwood, 124 Ohio St.3d 365, 922 N.E.2d 923 (Ohio 2010) (a jointly recommended sentence is unreviewable under R.C. 2953.08(D)(1) only if it comports with all mandatory sentencing provisions)
State v. Dean, 146 Ohio St.3d 106, 54 N.E.3d 80 (Ohio 2015) (offenses occurring on different days/locations and involving different victims are not a single transaction)