State v. Welsh, 2019 Ohio 4128

Defendant Zachary Welsh shot and killed the victim during an armed robbery and rearranged the scene to suggest suicide.
Welsh admitted shooting to police but claimed self-defense; he was charged with murder, aggravated robbery, felonious assault, and tampering with evidence.
The trial court denied Welsh's motion to suppress his statements and found him competent to stand trial.
Welsh entered a plea agreement pleading to involuntary manslaughter (with a firearm specification), aggravated robbery, and two counts of tampering; the parties agreed to a jointly-recommended aggregate 30-year sentence.
At the plea and sentencing hearings the state and defense expressly agreed the offenses did not merge and that Welsh would waive any merger/allied-offense arguments so the court could impose the agreed consecutive terms.
Welsh appealed claiming the convictions were allied offenses of similar import; the court affirmed, finding he waived the protections of R.C. 2941.25.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by convicting and sentencing Welsh on multiple offenses that are allied offenses of similar import	State: Parties contractually agreed offenses do not merge so the agreed 30-year consecutive sentence is authorized	Welsh: The offenses are allied under R.C. 2941.25 and should have merged into a single conviction	Court: Welsh waived allied-offense protection on the record; plea/sentencing agreement relieved court of merger obligation, so convictions and consecutive sentences stand

State v. Underwood, 124 Ohio St.3d 365 (establishes that a jointly-recommended sentence is reviewable only if it fails to comply with mandatory sentencing provisions and that a defendant may waive allied-offense protections in a plea agreement)