State v. Sanders, 2014 Ohio 5115

Sanders pled no contest in March 2012 to five offenses and the court sentenced him to eight years, with child endangerment counts merged.
Sanders appealed the convictions in 2013 after a prior suppression ruling was affirmed.
In November 2013 Sanders, pro se, filed a motion for resentencing which the trial court denied.
This appeal challenges two sentencing-related issues arising from the resentencing denial.
The trial court’s rulings on those issues were reviewed for void-sentence and allied-offenses-merger arguments and the court to affirm.
The appellate court held that the sentence was not void and issues were barred by res judicata, affirming the judgment of the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to make R.C. 2929.14 findings renders the sentence void	Sanders contends the consecutive sentences were void for missing findings.	State argues mishandling does not void the sentence and is barred by res judicata.	Not void; barred by res judicata
Whether failure to merge allied offenses requires reversal or voiding the sentence	Sanders argues convictions were allied and should have merged for sentencing.	State asserts non-merger does not void a sentence and can be raised on direct appeal.	Not void; res judicata applies

State v. Holdcroft, 137 Ohio St.3d 526 (2013-Ohio-5014) (consecutive-sentence challenges on direct appeal)
State v. Bonnell, 140 Ohio St.3d 209 (2014-Ohio-3177) (consecutive sentences review; voidness not found)
State v. Burden, 9th Dist. Summit No. 27298 (2014-Ohio-4456) (res judicata bars repeat attacks on final judgment)
State v. Lowe, 9th Dist. Summit No. 27199 (2014-Ohio-1817) (res judicata applies to sentencing issues)
State v. Jones, 9th Dist. Summit No. 26854 (2013-Ohio-3710) (failure to merge allied offenses not void sentence)
State v. Abuhilwa, 9th Dist. Summit No. 25300 (2010-Ohio-5997) (allied-offense merger doctrine)