State v. Bollar, 220 N.E.3d 690

Marquis Bollar pleaded guilty to involuntary manslaughter, felonious assault, and having a weapon while under a disability; each count carried a firearm specification.
At sentencing the trial court merged the involuntary-manslaughter and felonious-assault counts as allied offenses but imposed a three-year prison term for each firearm specification tied to those counts.
The Fifth District Court of Appeals affirmed the sentence; a dissenting judge and other appellate decisions (Doyle, Roper) reached contrary results, prompting a certified conflict to the Ohio Supreme Court.
The question presented: whether R.C. 2929.14(B)(1)(g) authorizes imposing separate prison terms for multiple firearm specifications when the underlying felony counts have been merged under R.C. 2941.25.
The Ohio Supreme Court held that the plain language of R.C. 2929.14(B)(1)(g) requires imposing prison terms for the two most serious firearm specifications to which the offender pleaded guilty (or was convicted), even when the related underlying felonies were merged.
A dissent argued that merger under R.C. 2941.25 precludes sentencing on a specification attached to a merged count and would have remanded to shift the specification sentence to a nonmerged count.

Issue	State's Argument	Bollar's Argument	Held
Whether courts must impose separate prison terms for multiple firearm specifications under R.C. 2929.14(B)(1)(g) when the underlying felonies have been merged	R.C. 2929.14(B)(1)(g)’s plain text requires prison terms for the two most serious specifications pleaded or of which the offender is convicted, regardless of merger	A specification cannot be sentenced if its underlying offense was merged and not sentenced; Whitfield/Ford foreclose sentencing on merged counts	The Court affirmed: R.C. 2929.14(B)(1)(g) requires sentencing on the two most serious firearm specifications pleaded/convicted even if the underlying offenses merged; merger does not negate that statutory command

State v. Whitfield, 124 Ohio St.3d 319 (Ohio 2010) (held that for R.C. 2941.25 purposes a "conviction" has included a guilty finding plus imposition of sentence in the allied-offense context)
State v. Ford, 128 Ohio St.3d 398 (Ohio 2011) (described firearm specifications as sentence enhancements tied to predicate felonies)
State v. Doyle, 133 N.E.3d 890 (8th Dist. 2019) (held that a firearm specification attached to a merged offense does not survive merger)
State v. Cabrales, 118 Ohio St.3d 54 (Ohio 2008) (articulated allied-offense / similar-import framework)
RadLAX Gateway Hotel, L.L.C. v. Amalgamated Bank, 566 U.S. 639 (U.S. 2012) (canon: specific or later-enacted statute can control over a general or earlier one)