State v. Rammel, 2012 Ohio 3724

Defendant Matthew Rammel burglarized two homes on Croftshire Drive and two on Harwich Court in Kettering in September–October 2010, with a later Croftshire burglary for a second time.
Police recovered stolen property during investigations and located some items in area pawn shops.
Detective Pedro observed Defendant entering Jenkins's workplace with a pillowcase and later saw necklaces removed from it.
Detective Walker arrested Defendant for burglary and receiving stolen property; Defendant consented to an interview after waiving Miranda rights, but later invoked the right to remain silent.
Defendant was indicted in two cases, pled no contest to all pending charges under a joint five-to-eight-year sentencing agreement, and received an aggregate eight-year sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether joinder of charges was proper or required severance	Rammel challenged severance; the State sought joinder	Joinder prejudiced fairness; severance required	Joinder proper; no abuse of discretion
Whether the overheard statements via Jenkins’s assistance were admissible	Evidence admissible under consent to interception	Consent not voluntary	Consent voluntary; statements admissible
Whether consecutive terms were properly imposed	Consecutive terms necessary to meet sentence range	Court lacked authority to impose consecutive terms	Agreed sentence governs; error not reviewable
Whether the agreed eight-year sentence was properly fashioned given the charges and ranges	Eight-year aggregate within agreed range	Sentence violates law or discretion	Agreed sentence not reviewable; within law and range

Lott, 51 Ohio St.3d 60 (1990) (joinder/severance standards; abuse of discretion)
Huffman v. Hair Surgeon, Inc., 19 Ohio St.3d 83 (1985) (abuse of discretion standard for trial court rulings)
State v. Torres, 66 Ohio St.2d 340 (1981) (joinder of offenses; policy considerations)
State v. Schaim, 65 Ohio St.3d 51 (1992) (analysis of joined offenses and jury confusion)