State v. Corker, 2013 Ohio 5446

Defendant Ja Michael Corker was charged in three indictments arising from separate early-2012 incidents: a January 1 robbery/kidnapping at a Sunoco (victim: Larry Fraganato), a February 3 Walmart assault/robbery attempt, and a February 4 shooting at Burnzie's Bar that injured two people.
Surveillance and witness testimony linked defendant across incidents by a distinctive black jacket with a white design; ballistic and video evidence tied him to the bar shooting.
A jury convicted Corker of aggravated robbery, kidnapping, two counts of robbery, four counts of felonious assault, and multiple firearm specifications.
Trial court sentenced Corker to an aggregate term (totaling 38 years including an unrelated term).
On appeal Corker raised three assignments: (1) improper joinder of the three indictments; (2) improper multiple convictions for allied offenses; and (3) failure to make required findings before imposing consecutive sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Joinder of indictments	Joinder was proper because offenses were similar in character and evidence conserved resources	Joinder was plain error; incidents had different victims and were not same scheme/transaction	Affirmed: joinder permissible under Crim.R. 8/13; offenses were of similar character and evidence was simple and distinct, so no plain error
Prejudice from joinder / severance	State argued evidence was simple/distinct or would be admissible if severed	Corker claimed he might have testified in a separate trial and was prejudiced	Affirmed: defendant failed to demonstrate actual prejudice or provide requisite specifics; State showed minimal risk of jury confusion
Allied-offenses / multiple convictions	State maintained separate convictions appropriate because conduct produced distinct harms/separate animus	Corker argued certain convictions (kidnapping vs aggravated robbery) should merge	Affirmed: aggravated robbery and kidnapping did not merge because restraint/asportation was prolonged/secretive and showed separate animus
Consecutive-sentencing findings (R.C. 2929.14(C)(4))	State did not contest need to remand given precedent	Corker argued court failed to make required statutory findings before imposing consecutive terms	Reversed in part: trial court failed to make required findings; remanded for the court to consider and enter proper findings on the record

State v. Waddell, 75 Ohio St.3d 163 (1996) (plain-error standard for joinder consequences)
State v. Schaim, 65 Ohio St.3d 51 (1992) (standards for severance under Crim.R. 14)
State v. Torres, 66 Ohio St.2d 340 (1981) (procedural requirements for severance showing)
State v. Johnson, 128 Ohio St.3d 153 (2010) (allied-offenses merger test)
State v. Brown, 119 Ohio St.3d 447 (2008) (single-act/single-animus framework)
State v. Jenkins, 15 Ohio St.3d 164 (1984) (aggravated robbery may involve restraint)
State v. Logan, 60 Ohio St.2d 126 (1979) (when kidnapping and related offense are distinct)
State v. Moss, 69 Ohio St.2d 515 (1982) (separate animus/merger analysis)