State v. Chandler, 2020 Ohio 1371

Harold Chandler was charged with aggravated arson and burglary after breaking into Tracey Jackson’s apartment and setting her bed on fire, damaging the apartment and building.
Chandler pled guilty to attempted arson (for causing physical harm to the building) and burglary.
At sentencing the trial court imposed consecutive 36-month terms on each conviction.
Chandler argued the convictions were allied offenses under R.C. 2941.25 and should merge because they arose from a single course of conduct.
The trial court denied merger; Chandler appealed the merger ruling.
The court of appeals affirmed the denial of merger and dismissed a separate, abandoned appeal (C-190175).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether burglary and attempted arson are allied offenses requiring merger under R.C. 2941.25	State: offenses are of dissimilar import because the arson caused separate, identifiable property harm while burglary is an intrusion into the home	Chandler: single course of conduct and animus; offenses should merge	Court: No merger — offenses are dissimilar in import (separate harms); convictions may stand and be sentenced consecutively

State v. Ruff, 143 Ohio St.3d 114 (2015) (adopts the three-part allied-offense test: conduct, animus, and import; offenses of dissimilar import exist when each causes separate, identifiable harm)
State v. Harris, 92 N.E.3d 1283 (2017) (appeal may be dismissed where appellant abandons assignments of error)