State v. Kauffman, 2021 Ohio 3847

Kauffman was indicted in Darke C.P. No. 2020-CR-141 for improperly handling firearms in a motor vehicle (R.C. 2923.16(B), felony 4) and having weapons while under disability (R.C. 2923.13(A)(3), felony 3), based on a firearm and a prior drug-trafficking conviction.
He was released on bond, then while on bond was indicted in a separate case (2020-CR-229) for failure to comply with police (R.C. 2921.331(B), felony 3) and aggravated possession of methamphetamine (felony 5).
Kauffman pleaded guilty in the second case to failure to comply; the drug count was dismissed, and the court sentenced him to 12 months in prison.
The trial court sua sponte dismissed the earlier firearm indictment (2020-CR-141) under Crim.R. 48(B), stating on the record six reasons—chiefly that conviction would likely not produce additional prison time and prosecuting would burden resources and cause delay.
The State appealed, arguing the dismissal was an abuse of discretion because a conviction in 2020-CR-141 would produce mandatory consecutive prison time and other collateral consequences.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Kauffman)	Held
Whether the trial court abused its discretion by dismissing the indictment under Crim.R.48(B) over the State's objection	Dismissal improper because conviction in 2020-CR-141 would impose mandatory consecutive prison time (statutory), license suspension, and thus prosecution could change Kauffman's legal consequences	Dismissal justified due to practical concerns: Kauffman already sentenced to 12 months, prosecution would burden public defender docket, cause delays/costs, firearm would be forfeited, and COVID-19 delays made prosecution less warranted	Reversed: dismissal was an abuse of discretion because a conviction would require consecutive sentencing and change Kauffman's legal exposure, so insufficient reasons did not exist to dismiss

State v. Busch, 76 Ohio St.3d 613 (abuse-of-discretion standard for trial-court dismissals under Crim.R. 48(B))