State v. Love, 2014 Ohio 1603

Appellant convicted by a jury of five felonies: aggravated robbery with firearm spec, felonious assault with firearm spec, tampering with evidence, aggravated trafficking in drugs, and having weapons while under a disability.
Two firearm specifications were imposed; the defendant was acquitted of receiving stolen property.
The aggregate sentence was 23 years, with underlying offenses largely run consecutively and some sentences concurrent to others.
State alleged the incident was a drug deal that shielded a robbery; eyewitnesses testified to gun-brandishing and theft, though some denied drug involvement.
On appeal, Appellant challenged sufficiency of the evidence for aggravated robbery and alleged harmful error in sentencing.
Trial court denied Crim.R. 29(A) acquittal; matter proceeded to appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the aggravated robbery conviction supported by sufficient evidence?	Love argues predicate theft lacking; firearm use tied to drug deal, not theft.	Love contends no theft predicate, and weapon use cannot satisfy aggravated robbery.	Sufficient evidence supported the conviction.
Was there harmful error in sentencing, including merger and firearm specifications?	Love claims improper merging and improper firearm-spec sentencing.	Love argues two separate issues: no merge due to separate victims; firearm specs improperly ordered.	No harmful error; sentences properly imposed and merged only where allowed.

State v. Johnson, 128 Ohio St.3d 153 (2010-Ohio-6314) (merger analysis reset; single vs. multiple allied offenses)
State v. Nguyen, 4th Dist. Athens No. 12CA14 (2013-Ohio-3170) (merger framework for allied offenses; Johnson lineage)
State v. Isreal, 2012-Ohio-4876 (12th Dist. Warren) (R.C. 2929.14(B)(1)(g) firearm-spec guidance)
State v. Ayers, 2013-Ohio-2641 (12th Dist.) (firearm specifications running consecutive under statute)
State v. Sheffey, 2013-Ohio-2463 (8th Dist.) (consecutive firearm-spec sentencing authority)
State v. Vanderhorst, 2013-Ohio-1785 (8th Dist.) (application of 2929.14(B)(1)(g) to multiple specs)