State v. Peterson, 2016 Ohio 1334

Luke Peterson, bound over from juvenile court, was indicted on four counts of aggravated robbery with accompanying firearm specifications and one count of carrying a concealed weapon.
Peterson pleaded guilty to four counts of aggravated robbery and one firearm specification; remaining counts/specifications were dismissed.
Trial court sentenced Peterson to an aggregate nine-year prison term (six years on each aggravated robbery count).
Peterson appealed, raising two errors: (1) improper sentencing (failure to consider statutory factors) and (2) failure to merge allied offenses.
The presentence investigation (PSI) and Aid in Sentencing reports were not included in the appellate record despite a motion to supplement.
The Ninth District affirmed the trial court’s judgment in both respects and taxed costs to appellant.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Peterson)	Held
Whether the trial court erred in sentencing by failing to consider R.C. 2929.11/2929.12 factors	Trial court properly considered sentencing factors; record supports sentence	Trial court failed to consider R.C. 2929.12(C)(2)-(4), so sentence is erroneous	Affirmed — appellate review presumes trial court considered statutes; appellant failed to include PSI to rebut presumption, so sentence not reversed
Whether multiple aggravated robbery counts should merge as allied offenses under R.C. 2941.25	Offenses are distinct and may be separately punished because they involved separate victims	Peterson argued offenses were allied and should have merged for sentencing	Affirmed — offenses involved four separate victims and thus are of dissimilar import; no merger required

State v. Ruff, 143 Ohio St.3d 114 (Ohio 2015) (framework for determining allied offenses under R.C. 2941.25)