State v. Hight, 2011 Ohio 5013

Appellant was indicted on one count of assaulting a police officer (felony of the fourth degree), one count of domestic violence (misdemeanor of the fourth degree), and one count of obstruction of official business (felony of the fifth degree).
Appellant pled guilty to all charges in exchange for sentencing, following a domestic dispute in which he resisted police during a welfare check at his home.
Officers encountered Appellant hiding under a bed; he fought Officers Henery and Stanford, resulting in their being assaulted during the initial encounter inside the residence.
Appellant fled the residence, continuing to struggle with additional officers outside, and was ultimately taken into custody.
The trial court sentenced Appellant to 15 months for assault and 9 months for obstruction, to be served consecutively, with 30 days for domestic violence served concurrently with the felony counts.
Appellant argued the assault and obstruction counts were allied offenses of similar import and should merge for sentencing; the court disagreed and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the convictions allied offenses of similar import requiring merger under R.C. 2941.25(A)?	State argues merger required; offenses were allied.	Hight contends the offenses were allied and should merge.	No merger; offenses were committed by separate conduct outside/inside the residence.

State v. Johnson, 128 Ohio St.3d 1405 (2010-Ohio-6314) (updated test for allied offenses of similar import under 2941.25(A))
Blankenship v. W., 38 Ohio St.3d 119 (1989) (discusses single act vs. multiple offenses and potential overlap)