State v. Knight, 2016 Ohio 7991

Knight and an accomplice robbed a Papa John’s while employees were present, using a firearm; employees were duct-taped and forced into a freezer.
After removing the manager at gunpoint, the men forced him to open the store vault and stole money; they later returned the manager toward the freezer.
Knight struck the manager on the side of the head with the gun ("pistol-whipped" him), causing physical injury; police arrested Knight nearby and recovered stolen items.
Knight pleaded guilty to aggravated robbery (with a firearm specification), kidnapping, and felonious assault; other counts were dismissed. He waived a factual recitation at plea.
At sentencing the court merged kidnapping into aggravated robbery but declined to merge felonious assault into aggravated robbery and imposed consecutive terms for a total of 15 years.
Knight appealed, arguing the convictions should have merged as allied offenses under R.C. 2941.25.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether felonious assault and aggravated robbery are allied offenses requiring merger	State: offenses did not merge because they involved separate conduct and harm	Knight: both offenses were against the same victim with a single animus and should merge	Court: No merger — robbery and assault were separate in conduct and harm; convictions affirmed

State v. Ruff, 143 Ohio St.3d 114 (2015) (sets three-factor allied-offense analysis: conduct, animus, import)
State v. Washington, 137 Ohio St.3d 427 (2013) (courts must review the entire record when deciding merger questions)
State v. Johnson, 128 Ohio St.3d 153 (2010) (allied-offense results depend on factual circumstances and may vary case-by-case)