State v. Stanifer, 2017 Ohio 2721

In 2006 Chad South broke into a Geauga County home, bound two occupants (Daniel Ott and Mary Anne Ricker), and shot Ott, who later died; South then fled to a getaway car driven by Mindie Stanifer.
South later told inmates he had been hired to kill “Dan Ott”; investigators located Stanifer in Florida in 2014.
Stanifer initially denied involvement but later admitted she was in the car, saw South covered in blood, and claimed she thought they were committing a burglary while she was addicted to drugs.
In December 2015 Stanifer was indicted on multiple counts including aggravated murder, kidnapping (two counts), conspiracy, and obstruction of justice; she pled guilty in May 2016 to involuntary manslaughter (lesser included), one count of kidnapping, and two obstruction counts; other counts were dismissed.
The trial court imposed consecutive terms totaling 18 years (8 + 6 + 1.5 + 2.5 years), and Stanifer appealed, raising (1) that the sentencing findings under R.C. 2929.14(C)(4), 2929.11, and 2929.12 were not supported, and (2) that involuntary manslaughter and kidnapping were allied offenses requiring merger.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Stanifer)	Held
Whether the court’s consecutive‑sentence findings under R.C. 2929.14(C)(4) and consideration of R.C. 2929.11/2929.12 were supported by the record	Record supports findings; court considered statutory factors, defendant’s record, victim impact, and reasons for consecutive terms	Sentences contrary to law because the statutory findings were not clearly and convincingly supported	Affirmed — court made required findings at hearing and in entry; sentencing within statutory ranges and complied with statutes
Whether involuntary manslaughter and kidnapping were allied offenses requiring merger	Offenses are dissimilar (separate harms, two victims, kidnapping facilitated the felony) so separate punishments permitted	Manslaughter and kidnapping should merge because they arise from the same conduct	Affirmed — offenses are dissimilar in import (separate, identifiable harms and victims) and not subject to merger

Bonnell v. Ohio, 140 Ohio St.3d 209 (court must make statutory consecutive‑sentence findings at hearing and incorporate them into the entry; no required rote recitation of statute)
Underwood v. Ohio, 124 Ohio St.3d 365 (R.C. 2941.25 protects against multiple punishments; merger doctrine explained)
Ruff v. Ohio, 143 Ohio St.3d 114 (adopted multi‑factor test: offenses may be separately punished if dissimilar in import, committed separately, or with separate animus)
Whitfield v. Ohio, 124 Ohio St.3d 319 (failure to merge allied offenses requires reversal and remand for election at resentencing)
Botta v. Ohio, 27 Ohio St.2d 196 (discusses merger/penal philosophy that major crimes can subsume component offenses)