State v. Redden, 2020 Ohio 878

Police investigated James Redden after NPlex records and surveillance linked him and associates to multiple pseudoephedrine purchases and suspected meth “cook” activity at 506 W. Tenth St.; searches of 506 and adjacent 502 recovered items consistent with meth manufacture.
Detectives stopped Redden on the street (phase one), then Mirandized him and later questioned him again at the residence during execution of a warrant (phase two) and at the county jail (phase three); the trial court suppressed phase-one statements but admitted phases two and three.
Redden was indicted on Count I: illegal manufacture (2nd-degree felony); Count II: illegal assembly/possession of chemicals to manufacture (3rd-degree felony); and Count III: aggravated trafficking (4th-degree felony).
A jury convicted Redden on all counts; sentencing imposed consecutive terms (5 years Count I, 2 years Count II, 18 months Count III) plus a 12-month PRC sanction for an aggregate 9.5 years.
On appeal the court affirmed the suppression ruling in part, found trial counsel ineffective for failing to seek waiver of mandatory fines via affidavit of indigency (vacating fines remand), and concluded Counts I & II are allied offenses that must merge for sentencing (vacating those sentences and remanding for resentencing).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post‑Miranda statements (phases two/three) were tainted by pre‑Miranda roadside questioning (Seibert claim)	Evans’s midstream Miranda and later statements were admissible; no single unwarned sequence	All statements should be excluded as continuous interrogation begun in phase one	Court: affirmed suppression only for phase one; phases two and three admissible—no Seibert violation (distinguishable facts, attenuation)
Whether trial counsel was ineffective for failing to file affidavit of indigency/move to waive mandatory fines	No prejudice; trial court properly considered ability to pay	Counsel’s failure was deficient and prejudicial given indigency indicators and Davis guidance	Court: counsel ineffective as to fines; remanded for indigency hearing regarding waiver of mandatory fines
Whether Counts I (manufacture) and II (assembly/possession of chemicals) are allied offenses that must merge	Prosecution treated same conduct as proving both offenses; harms not separate	Offenses reflect distinct conduct/timing (possession vs manufacture)	Court: Counts I and II are allied; sentences on those counts vacated and remanded for election/resentencing

Miranda v. Arizona, 384 U.S. 436 (establishes custodial‑interrogation warnings and waiver analysis)
Missouri v. Seibert, 542 U.S. 600 (holds midstream Miranda warnings can be ineffective; sets factors for evaluating "question‑first" technique)
State v. Ruff, 143 Ohio St.3d 114 (defines allied‑offense test: separate victims or separate, identifiable harms or separate animus)
State v. Rogers, 143 Ohio St.3d 385 (addresses forfeiture of allied‑offense claims and plain‑error review)
State v. Farris, 109 Ohio St.3d 519 (discusses application of Seibert and when post‑warning statements are tainted)