State v. Ellis, 2014 Ohio 4812

Ellis pled guilty to Counts 2, 5, 7, 8, 10, and 12–15 and the remaining counts were dismissed.
The indictment contained 15 counts related to a home invasion against Richard and Margaret Kovachik, each count carrying firearm specifications; Counts 13 and 15 carried elderly-victim enhancements.
The trial court sentenced Ellis to a total of 25 years with two 3-year firearm-spec terms preceding consecutive terms for other offenses; costs were entered in the journal entry.
Ellis appealed on four assignments of error: (I) allied-offense merger; (II) misinterpretation of firearm-spec provisions; (III) improper court-cost imposition; (IV) lack of proportionality/consistency analysis and unsupported consecutive-term findings.
The State conceded that the third assignment has merit; the court remanded to consider whether costs should be imposed, but otherwise affirmed the sentence.
The appellate court affirmed in part, reversed in part, and remanded for resentencing consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether allied offenses merge under R.C. 2941.25	Ellis contends counts are allied offenses with a single animus.	Ellis argues the offenses should have merged for sentencing.	Offenses committed separately with separate animus; no merger.
Interpretation of R.C. 2929.14(B)(1)(g) and firearm specs	Ellis and counsel allegedly misconstrued the statute to require consecutive specs.	Counsel contested the court’s interpretation of the statute.	Court correctly applied the statute; no merit to ineffectiveness claim.
Imposition of court costs	Costs were imposed in the journal entry despite no sentencing-hearing mention.	Ellis argued the journal-entry costs were improper.	Costs reversal; remanded to consider waiver of costs.
Overall sentence and compliance with proportionality/legislative factors	Ellis claims lack of proper proportionality analysis and statutory consideration.	Record supports reasons under 2929.11 and 2929.12.	Sentence not clearly contrary to law; remanded for resentencing consistent with the opinion.

State v. Johnson, 128 Ohio St.3d 153 (Ohio 2010) (establishes allied-offense analysis under R.C. 2941.25)