State v. Blackford, 2012 Ohio 4956

Blackford convicted on four kidnapping counts, two aggravated burglaries, and four aggravated robbery counts.
He pleaded guilty to one aggravated burglary, one aggravated robbery, and four kidnapping counts (2009).
Sentenced November 23, 2009: consecutive terms totaling 14 years (burglary 3, robbery 3, kidnapping 2 each).
February 1, 2012: he moved for delayed appeal; this court granted review.
Appeal challenges: consecutive kidnapping sentences, failure to merge kidnapping with robbery, and ineffective assistance of counsel.
Appellate court majority affirmed; dissents discussed potential remand for Johnson-based analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consecutive kidnapping sentences valid?	Blackford	Blackford	Consecutive sentences improper under 2941.25 and double jeopardy.
Should one kidnapping count merge with aggravated robbery?	State	Blackford	No merger; counts not allied offenses under Johnson framework.
Were counsel's actions ineffective for failing to object to non-merger?	State	Blackford	No ineffective-assistance violation; trial counsel presumed reasonable.

State v. Johnson, 128 Ohio St.3d 153 (Ohio Supreme Court 2010) (overruled Rance; conduct-focused allied offenses test)
State v. Rance, 85 Ohio St.3d 632 (Ohio Supreme Court 1999) (original allied offenses framework (overruled))
State v. Nickel, 2011-Ohio-1550 (Ohio) (Johnson-based analysis applied to merger)
State v. Harvey, 2010-Ohio-5408 (Ohio) (premised on multiple kidnapping counts; aiding merger discussion)
State v. Winn, Ohio St.3d 2010 (Ohio Supreme Court 2009) (kidnapping and aggravated robbery allied per Winn; pre-Johnson)
State v. Miller, 2011-Ohio-1161 (Ohio) (Johnson analysis; lacks full record for conduct)
State v. Grice, 2012-Ohio-1938 (Ohio) (presumption of regularity; burden on appellant)
State v. Underwood, 2010-Ohio-1 (Ohio) (plain-error standard for multiple sentences)