State v. Sanderfer, 2015 Ohio 4285

On August 7, 2014 Steven Sanderfer shot Gerrice Stallworth inside a residence after confronting him about a stolen stereo; Stallworth survived and reported Sanderford as the shooter.
Sanderfer was arrested 11 days later and indicted on two counts of felonious assault (one alleging serious physical harm, one alleging use of a deadly weapon) each with firearm specifications, and one count of having weapons while under disability.
A jury convicted Sanderfer of both felonious-assault counts (which the trial court merged) and the weapons-under-disability count.
At sentencing the court merged the two felonious-assault counts, imposed a mandatory firearm specification term, and imposed a consecutive prison term for the weapons-under-disability conviction, resulting in a total 14-year sentence (consecutive to another case).
Sanderfer appealed arguing the weapons-under-disability conviction should have merged with the felonious-assault conviction as allied offenses of similar import under R.C. 2941.25.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether having a weapon while under disability and felonious assault are allied offenses requiring merger under R.C. 2941.25	State: convictions may stand separately because the offenses involve distinct conduct and harms	Sanderfer: both convictions arise from the same conduct (possession/use of the firearm) and same animus, so they must merge	Court: Affirmed — offenses do not merge because possession/acquisition of the firearm (having weapon while under disability) is separate conduct with a separate animus from the later shooting (felonious assault).

State v. Ruff, 143 Ohio St.3d 114 (2015) (establishes allied-offense test requiring evaluation of conduct, animus, and import; offenses that cause separate identifiable harm or involve separate victims or separate animus do not merge)
State v. Johnson, 128 Ohio St.3d 153 (2010) (discusses allied offenses and merger principles under Ohio law)