State v. Hayes, 2014 Ohio 5362

Hayes pled guilty to having weapons under disability and possession of heroin with a firearm specification under a plea agreement.
The indictment charged three counts, including weapons under disability, improper handling of firearms in a motor vehicle, and possession of heroin with a firearm specification.
The trial court imposed consecutive prison terms totaling 59 months (30 for weapons under disability, 17 for heroin, 12 for the firearm spec).
The State dismissed the firearm-vehicle handling count as part of the plea.
Hayes appeals challenging the consecutive-sentence findings and whether the firearm specification must merge with the underlying offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consecutive sentences proper under R.C. 2929.14(C)(4)?	Hayes contends lack of explicit findings.	Hayes argues findings were mere recitation of statutory language.	Findings were made and incorporated; not clearly unsupported.
Do weapons under disability and firearm specification merge?	Beal/Johnson framework shows potential merger.	Firearm spec is a penalty enhancement, not a separate offense.	No merger; firearm spec must be served consecutively to the underlying felony.

State v. Rodeffer, 2013-Ohio-5759 (2d Dist. Ohio 2013) (limits of appellate review under G(2) standard)
State v. Bonnell, 2014-Ohio-3177 (Ohio 2014) (consecutive-sentence findings need not state reasons, must have record support)
State v. Beal, 2014-Ohio-3834 (2d Dist. Ohio 2014) (firearm specification not merged with its predicate offense)
State v. Johnson, 2010-Ohio-6314 (Ohio Supreme Court 2010) (allied-offense framework; merger analysis)
State v. Ford, 2011-Ohio-765 (Ohio Supreme Court 2011) (firearm specification as penalty enhancement; merger not allowed)