State v. Gibson, 2014 Ohio 136

Gibson pled guilty to Theft from an Elderly Person or Disabled Adult and eight Forgery counts; other charges were dismissed; total sentence 24 months.
Eight Forgery counts involved elderly grandfather as victim and were tied to a scheme; the Theft count aggregated multiple offenses.
R.C. 2913.61(C)(1) mandates aggregation within a single employment/relationship; (C)(2) permits aggregation across a scheme.
The State contends Forgery counts could be aggregated under (C)(2); Gibson argues all related offenses should be one.
Court concludes Forgery counts must be aggregated under (C)(1) but need not be aggregated with the Theft offense; no plain error.
Judgment affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether eight Forgery counts must be aggregated under 2913.61(C)(1) or (C)(2).	State: aggregation possible under (C)(2).	Gibson: aggregation mandatory.	Forgery counts must be aggregated under (C)(1); not required to aggregate with Theft.
Whether failure to aggregate amounts to plain error.	State argues misstep would affect sentence.	Gibson argues any error warrants reversal.	No plain error; harm not shown; sentence affirmed.
Whether the two statutory series (Forgery vs Theft) are to be aggregated together.	State seeks one overarching aggregation of all offenses.	Gibson urges separate aggregations per series.	Two series aggregated separately; not necessary to combine into a single offense.

State v. Long, 53 Ohio St.2d 91 (1978) (plain-error standard guidance in criminal appeals)
State v. Doll, 24 Ohio St.2d 130 (1970) (emphasizes fiduciary/trust-based rationale for aggregation under embezzlement lineage)
State v. Rice, 103 Ohio App.3d 388 (1995) (aggregation in ongoing relationship contexts)