State v. Boyd, 2020 Ohio 5181

On Jan. 1, 2019, Cardell Boyd stabbed his wife with a butcher knife, sprayed and poured gasoline on her, attempted to set her on fire, and later accelerated a car toward her; neighbors intervened and she survived with serious injuries (collapsed lung, stab wounds, gasoline in lungs).
Boyd was on community control for a prior domestic-violence conviction against the same victim when he committed these acts and has an extensive criminal history.
In May 2019 Boyd pleaded guilty to six counts: two counts of felonious assault (knife and vehicle), attempted aggravated arson, abduction, domestic violence (merged), and aggravated menacing (misdemeanor).
At sentencing the court admitted photographic evidence, heard victim impact and mitigation, and imposed an aggregate 17-year prison term (7 yrs knife, 3 yrs vehicle, 7 yrs attempted arson, 2 yrs abduction, 178 days for menacing; domestic violence merged).
Boyd appealed, arguing (1) his individual and consecutive sentences were contrary to law and unsupported by the record (R.C. 2929.11/2929.12 and 2929.14(C)(4)), and (2) the felonious-assault and abduction counts were allied offenses and should have merged.
The Eighth District affirmed, holding the trial court considered statutory sentencing factors, made the required consecutive-sentence findings, and that the offenses were not allied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of individual sentences (R.C. 2929.11/2929.12)	State: sentences within statutory ranges and supported by record and harms.	Boyd: trial court failed to adequately consider/recite R.C. 2929.11 and 2929.12; mitigation favors shorter terms.	Court: trial court considered required factors; record clearly and convincingly supports the individual terms.
Consecutive sentences (R.C. 2929.14(C)(4))	State: court made required findings and record supports necessity, proportionality, and statutory predicate (on probation).	Boyd: court did not adequately explain or the record does not support consecutive terms; mitigation weighs against them.	Court: trial court expressly found necessity, proportionality, and that offenses occurred while on probation; record clearly and convincingly supports consecutive terms.
Allied-offense merger (R.C. 2941.25 / Ruff test)	State: offenses arose from separate acts (stabbing, dragging/abduction, attempted vehicular assault/arson) with separate conduct/animus.	Boyd: felonious assault and abduction flowed from a single continuous animus against one victim and should merge.	Court: under Ruff, the acts were separate decisions and separate conduct; offenses not allied and need not merge.

State v. Marcum, 59 N.E.3d 1231 (Ohio 2016) (standard for appellate review of sentences under R.C. 2929.11/2929.12).
State v. Foster, 845 N.E.2d 470 (Ohio 2006) (no need for trial court to make explicit R.C. 2929.11/2929.12 findings on the record for sentences within statutory range).
State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) (trial court must make/find the R.C. 2929.14(C)(4) factors for consecutive sentences; findings must be in the record/entry).
State v. Ruff, 34 N.E.3d 892 (Ohio 2015) (allied-offense test: dissimilar import, separate conduct, or separate animus permits multiple convictions).
State v. Cabrales, 886 N.E.2d 181 (Ohio 2008) (R.C. 2941.25 and merger principles).
Missouri v. Hunter, 459 U.S. 359 (U.S. 1983) (double jeopardy prohibits greater punishment than legislature intended; statutory intent controls multiple punishments).
State v. Childs, 728 N.E.2d 379 (Ohio 2000) (focus on legislative intent whether multiple punishments are permitted).