State v. Ramsey, 2013 Ohio 2124

Ramsey was charged in a multi-count indictment for offenses in January 2012 and moved for relief from prejudicial joinder seeking severance of counts.
The trial court ordered competency evaluations; Ramsey was found competent to stand trial.
Plea negotiations were ongoing; the State offered a plea to multiple counts with dismissal of some charges and a 12–15 year sentencing range.
Ramsey entered a no contest plea after the judge indicated severance would not be ruled on before trial due to ongoing negotiations.
At sentencing, Ramsey received a total term of twelve years after the plea; the motion to sever had not been ruled on at the plea or sentencing hearings.
Ramsey assigns error to the court’s failure to rule on the motion to sever prior to accepting the plea, challenging the validity of the plea under Crim.R. 11(C)(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by not ruling on the severance motion before sentencing.	Ramsey contends the court should have ruled on severance pre-trial.	State argues no prejudice shown; plea entered with knowledge of severance status.	No error; plea was knowingly, intelligently, and voluntarily made.

Clark, 119 Ohio St.3d 239 (2008) (Crim.R. 11(C)(2) compliance for plea validity)
State v. Payne, 2003-Ohio-4891 (Ohio Supreme Court (2003)) (joinder and severance discussed in the context of efficiency and fairness)
State v. Thomas, 61 Ohio St.2d 223 (1980) (joinder of offenses and severance principles in Ohio)