State v. Smith, 2019 Ohio 5326

1989 indictment charged Myron Smith with three counts of aggravated murder (each with death specifications), one count of aggravated robbery, and one count of kidnapping for the murder of Betty Calloway; a jury convicted on all counts.
At sentencing the trial court found the three aggravated-murder counts merited merger and stated it would impose a single term of life with no parole eligibility for 30 years as to Counts I, II, and III; it also imposed consecutive 10–25 year terms for robbery and kidnapping.
On appeal (Smith I) this court reversed and merged the kidnapping count as an allied offense; the trial court entered a 1996 modified judgment vacating the kidnapping conviction.
Smith later filed multiple postjudgment motions (2012–2019) challenging the sentencing entry; prior appeals rejected some challenges as barred by res judicata.
In 2019 Smith moved for resentencing, arguing the court improperly sentenced all three aggravated-murder counts (violating R.C. 2941.25(A)) and improperly used the federal "sentencing-package" doctrine; the trial court denied the motion and Smith appealed.
The Tenth District affirmed: it concluded the trial court had imposed a single sentence for the merged aggravated-murder counts and that the sentencing-package doctrine does not apply in Ohio.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court improperly convicted/sentenced Smith on all three aggravated-murder counts instead of only one under R.C. 2941.25(A)	State: Court properly merged the three counts and imposed one life term; merger authority does not depend on a prosecution election	Smith: Prosecution failed to elect which allied offense to pursue, so multiple convictions/sentences violated R.C. 2941.25(A)	Affirmed — court found a single sentence was imposed for Counts I–III; merger by the court was proper and not contingent on a state election
Whether the sentencing-package doctrine was applied (invalidly)	State: Doctrine is inapplicable in Ohio and the trial court did not rely on it	Smith: Sentence was a bundled/multi-count package and infected by error	Affirmed — Ohio Supreme Court rejected the sentencing-package doctrine for Ohio sentencing; Saxon controls

State v. Whitfield, 124 Ohio St.3d 319 (2010) (R.C. 2941.25 incorporates double-jeopardy protections against multiple punishments)
Maumee v. Geiger, 45 Ohio St.2d 238 (Ohio 1976) (prosecution has the right to elect which allied offense to pursue)
State v. Williams, 148 Ohio St.3d 403 (2016) (separate sentences for allied offenses are contrary to law and void; void sentences may be corrected at any time)
State v. Singleton, 124 Ohio St.3d 173 (2009) (holding that unlawful multiple sentences are void)
State v. Saxon, 109 Ohio St.3d 176 (2006) (Ohio Supreme Court rejects the federal sentencing-package doctrine for Ohio sentencing)
United States v. Clements, 86 F.3d 599 (6th Cir. 1996) (illustrative federal case describing the sentencing-package doctrine)