State v. Lanier, 950 N.E.2d 600

Lanier was convicted of attempted murder and two felonious‑assaults with firearm specifications; sentences were imposed on all three offenses.
On appeal, Lanier contended the three offenses were allied offenses of similar import and should have merged for sentencing.
The appellate court initially affirmed guilt but vacated sentences and remanded for resentencing, applying a Cabrales/Cóbrales framework.
Lanier’s offenses involved two felonious assaults under different subsections and attempted murder; later opinions by higher courts shifted the analysis.
Subsequent state supreme court rulings (Love, Williams, Johnson) altered the allied-offenses framework governing these conclusions.
The court ultimately held the three offenses were allied under the Johnson/Craycraft approach and must be merged for sentencing, vacating the prior sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether attempted murder and felonious assault are allied offenses of similar import	Lanier argued the offenses are allied and should merge.	Lanier contends same conduct supports merger; the state disputes that they are allied.	All three offenses are allied and must merge for sentencing.
What test governs allied offenses post Johnson	Lanier relies on pre‑Johnson framework to merge.	State adopts Johnson/Craycraft two‑part test requiring same conduct and single act with single animus.	Court adopts Johnson/Craycraft two‑part test; conduct can support all three offenses and may be a single act with a single state of mind.
Whether the offenses were committed by a single act or separate acts	The shooting involved continuous actions with a single intent.	The three offenses could be treated as separate punishments if separate animus existed.	The offenses were committed by a single act with a single state of mind; they are allied and merge.
Proper remedy for merged offenses	All three offenses should be merged into one conviction for sentencing.	Only one sentence should be imposed for the merged offenses.	Sentences vacated; remanded for resentencing on a single offense consistent with the opinion.

State v. Lanier, 180 Ohio App.3d 376 (2008-Ohio-6906) (original Lanier contention on allied offenses)
State v. Cabrales, 118 Ohio St.3d 54 (2008-Ohio-1625) (infrastructural framework for allied offenses)
State v. Love, 2009-Ohio-1079 (1st Dist.) (conflicted with Lanier on allied offenses; later overruled in part)
State v. Williams, 124 Ohio St.3d 381 (2010-Ohio-147) (Supreme Court decision on allied offenses)
State v. Johnson, 128 Ohio St.3d 153 (2010-Ohio-6314) (overruled prior Love/Craycraft‑based approach; new Johnson framework)
State v. Craycraft, 2011-Ohio-413 (12th Dist.) (articulates two‑part test for allied offenses under Craycraft)
State v. Rance, 85 Ohio St.3d 632 (1999) (earlier related authority for allied-offense analysis)