State v. Chandler, 2016 Ohio 1017

Keith Chandler was indicted on one count of Tampering with Records (R.C. 2913.42), one count of Forgery (R.C. 2913.31), and six additional Tampering counts relating to documents kept by Ohio government entities.
The State alleged Chandler altered his DD-214 to show he was a Purple Heart recipient and used that document to obtain and renew Purple Heart license plates over multiple occasions (2009–2013).
Chandler moved to dismiss, arguing the more specific misdemeanor Falsification statute (R.C. 2921.13(A)(5)) should preclude prosecution under the broader felony statutes under R.C. 1.51.
The trial court denied the motion; Chandler pleaded no contest to all counts and was sentenced to concurrent community-control sanctions.
On appeal Chandler contended the trial court erred by applying Tampering and Forgery rather than the specific Falsification offense; the court reviewed statutory-construction issues de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tampering with Records (felony) is irreconcilable with Falsification (misdemeanor) under R.C. 1.51	State: statutes are reconcilable; Tampering is the more specific offense for government-kept writings	Chandler: R.C. 1.51 mandates the special falsification statute prevail, so charges under broader felonies are improper	Court: Tampering and Falsification are reconcilable; Tampering is more specific and may be charged (affirmed)
Whether Forgery (felony by utterance) is displaced by Falsification	State: Forgery addresses the narrower conduct of creating/uttering forged writings	Chandler: overlapping elements mean falsification (special) should control	Court: Forgery is more specific as to authenticity acts and is reconcilable with falsification; convictions stand

State v. Volpe, 38 Ohio St.3d 191 (irreconcilable statutory provisions: special prevails absent contrary intent)
State v. Chippendale, 52 Ohio St.3d 118 (R.C. 1.51 applies when general and special provisions are allied offenses of similar import)
State v. Conyers, 87 Ohio St.3d 246 (irreconcilable statutes give inconsistent results and cannot both apply)
State v. Johnson, 128 Ohio St.3d 153 (allied-offense analysis clarified by Ohio Supreme Court)
State v. Ruff, 143 Ohio St.3d 114 (later guidance affecting allied-offense jurisprudence)
State v. Sufronko, 105 Ohio App.3d 504 (forgery invalidates authenticity of writing, distinct from falsification)
Akron Centre Plaza Ltd. Liab. Co. v. Summit Cty. Bd. of Revision, 128 Ohio St.3d 145 (statutory-construction and de novo review principles)