State v. Evans, 2026-Ohio-1237

Two masked men robbed a Verizon store, forced manager Crosby to lead them to the inventory room, and stole 38 phones worth about $31,420. 1
Store video and GPS tracking led police to Star Wireless, where officers found Evans, Williams, and Strattman with the stolen phones. 2
A search of the getaway car recovered Evans's identification, gloves, mask, hoodie, and bags matching items seen in the robbery videos. 3
A grand jury indicted Evans, Williams, and Strattman for aggravated robbery, kidnapping, grand theft, and possession of criminal tools, and the court convicted them after a joint bench trial. 4
The trial court merged grand theft into robbery, but imposed separate consecutive sentences for robbery, kidnapping, and criminal-tools offenses. 5
Evans and Williams appealed, challenging kidnapping sufficiency, merger, postrelease control advisements, and consecutive-sentence findings. 6
The court affirmed the convictions but reversed sentencing in part and remanded for resentencing. 7

Issue	Plaintiff's Argument	Defendant's Argument	Held
Kidnapping conviction supported by sufficient evidence and weight 8	Evans claimed he did not personally remove or restrain Crosby.	State argued Evans acted as Strattman's accomplice in the robbery.	Sufficient and not against the manifest weight; accomplice liability applied. 9
Kidnapping and robbery merger 10	Evans and Williams said Crosby's movement and restraint were incidental to robbery.	State said the restraint was prolonged and increased Crosby's risk.	Kidnapping and robbery were allied offenses and should merge. 11
Possession of criminal tools merger 12	Evans and Williams said bags, masks, and gloves were integral to robbery.	State said the tools were separate, supporting concealment and transport.	No merger; the offenses were committed separately. 13
Postrelease control advisement 14	Evans argued the court failed to orally advise him at sentencing.	State conceded the omission.	Sentence reversed in part and remanded for proper postrelease-control hearing. 15
Consecutive-sentence findings 16	Evans argued the court failed to make the third required R.C. 2929.14(C)(4) finding orally.	State said the court's reference to Evans's record satisfied the criminal-history finding.	Consecutive sentences were contrary to law; remand required. 17

State v. Jenks, 61 Ohio St.3d 259 (Ohio 1991) (sufficiency-of-the-evidence standard 18)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (manifest-weight standard and exceptional-case language 19)
State v. Logan, 60 Ohio St.2d 126 (Ohio 1979) (kidnapping restraint or movement incidental to another offense does not create separate animus 20)
State v. Martin, 20 Ohio App.3d 172 (1st Dist. 1983) (manifest-weight review asks whether the factfinder clearly lost its way 21)
State v. Jenkins, 15 Ohio St.3d 164 (Ohio 1984) (kidnapping is implicit within every robbery 22)