State v. Hunt, 108 N.E.3d 141

Chad A. Hunt, Jr. was indicted on trafficking (fifth-degree felony) and two possession counts: cocaine (first-degree felony) and heroin (fourth-degree felony); forfeiture of cash and firearms was also alleged.
Hunt pled guilty to all three counts; the trial court convicted him accordingly.
Sentencing: 10 months (trafficking), 8 years (cocaine-possession), 12 months (heroin-possession); court ordered consecutive terms for a total of 9 years, 10 months, and forfeited $2,180 plus other contraband.
Hunt appealed, arguing (1) the court failed to properly weigh mitigating factors and (2) the two possession convictions should merge as allied offenses sharing a single animus; he also challenged the imposition of consecutive sentences.
The appellate court reviewed the record for compliance with sentencing statutes (R.C. 2929.11, 2929.12, 2929.14) and merger law (R.C. 2941.25 as interpreted in Ruff).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion in weighing sentencing factors	State: Court properly considered R.C. 2929.11/2929.12 and explained findings at hearing and in entry	Hunt: Court failed to give adequate weight to mitigation (youth, remorse, no prior felonies, employment, substance abuse, legally owned firearms)	Affirmed: Court expressly considered relevant factors; explanation sufficed under precedent
Whether cocaine and heroin possession merge as allied offenses	State: Different drugs are separately classified and punishable; simultaneous possession can constitute multiple offenses	Hunt: Seizure of both drugs was same conduct/single animus so sentences should merge	Affirmed: Offenses are of dissimilar import; simultaneous possession of different controlled substances may support multiple convictions
Whether consecutive sentences were lawful	State: Court made required R.C. 2929.14(C)(4) findings at hearing and entry (necessity to protect public/punish; not disproportionate; multiple offenses part of course of conduct and offender history warrants consecutives)	Hunt: Consecutive terms were excessive/unwarranted	Affirmed: Court made oral and entry findings required by Bonnell; consecutive sentences supported
Whether any sentence was outside statutory range	State: Sentences fall within statutory ranges	Hunt: Implicit challenge to length	Affirmed: Each term was within the applicable statutory range

State v. Marcum, 146 Ohio St.3d 516 (Ohio 2016) (standard of appellate review for felony sentences)
State v. Ruff, 143 Ohio St.3d 114 (Ohio 2015) (test for allied offenses and when offenses may be separately punished)
State v. Delfino, 22 Ohio St.3d 270 (Ohio 1986) (simultaneous possession of different controlled substances can constitute multiple offenses)
State v. Bonnell, 140 Ohio St.3d 209 (Ohio 2014) (trial court must make required consecutive-sentence findings at the sentencing hearing and incorporate them into the entry)