State v. Williams, 2014 Ohio 725

Adam Williams was indicted on five counts of possession of cocaine and one count of trafficking cocaine arising from drugs found in a motel room; five possession-of-criminal-tools counts were dismissed as part of a plea deal.
Williams pleaded guilty to the six drug counts and was sentenced on October 19, 2010 to five years of community control with a reserved 12-month prison term per count (72 months total) if community control was revoked; he did not appeal that conviction/sentence.
The State moved to revoke community control in March 2012; Williams admitted violations at an evidentiary hearing and the court revoked community control on May 10, 2012.
On revocation the trial court imposed an aggregate 42-month prison term for the six offenses (less than the reserved 72 months originally discussed).
Williams appealed the revocation entry arguing his six convictions were allied offenses of similar import and should have merged (reducing the number of convictions/sentence).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams’s five possession counts and one trafficking count were allied offenses that should have merged	State: the allied-offense claim is barred by res judicata because it could have been raised on direct appeal from the original conviction	Williams: the offenses were allied and should have merged into fewer convictions (either two possession counts or one possession + one trafficking)	The court held the allied-offense claim is barred by res judicata because it was ripe after the original conviction and should have been raised on direct appeal; affirmed the revocation judgment

Szefcyk v. Ohio, 77 Ohio St.3d 93 (Ohio 1997) (establishes that final conviction bars defendant from raising in later proceedings any defense that was or could have been raised on direct appeal)
State v. Saxon, 109 Ohio St.3d 176 (Ohio 2006) (issues that could have been raised on direct appeal are barred by res judicata)