State v. Snuffer, 2011 Ohio 6430

Snuffer pleaded guilty in four cases to 15 theft counts and one forgery count.
He was the director of a program that disbursed government funds to the disabled and deposited less than full amounts while withdrawing funds for himself.
The four case numbers are CR-536812, CR-536868, CR-538335, CR-539285; total sentence was 12 years with restitution.
On appeal, Snuffer challenges merger of counts for sentencing and argues the sentence length constitutes an abuse of discretion.
The court held the theft counts in CR-538335 were not allied and could be separately punished; theft and forgery in CR-539285 were not allied with each other; plain-error review did not show merging error was obvious; the sentence was not an abuse of discretion; judgment affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by failing to merge allied offenses for sentencing.	Snuffer argues counts were allied offenses.	State contends no merger required given dissimilar victims/acts.	No plain-error merger; ten thefts not allied; dissimilar victims.
Whether the combined 12-year sentence was an abuse of discretion.	Not explicitly advanced beyond multi-year duration.	Two-year span shows long-term scheme supporting longer term.	Sentence within discretion; not an abuse.

State v. Johnson, 128 Ohio St.3d 153 (Ohio Supreme Court 2010) (allied-offense analysis based on same conduct with single animus)
State v. Phillips, 75 Ohio App.3d 785 (Ohio 1991) (dissimilar import for offenses against different victims)
State v. Jones, 18 Ohio St.3d 116 (Ohio 1985) (basis for allied-offense doctrine)
State v. Polk, 8th Dist. No. 88639, 2007-Ohio-4436 (Ohio 8th Dist. 2007) (application of allied offenses concept in multiple thefts)