State v. Williams, 2014 Ohio 1239

Williams was convicted by jury of two counts of aggravated murder and related offenses in the shooting death of Artemis Darden.
He received an aggregate sentence of 33 years to life with 5 years post-release control.
This court previously affirmed convictions but held aggravated-murder counts ought to merge; remanded for limited sentencing remand.
On remand, the sentencing hearing was limited to correcting the merger of the two aggravated-murder counts.
Williams moved for reopening; that motion was denied. The trial court conducted a limited resentencing and Williams sought further relief.
On appeal, Williams argued the trial court erred by not addressing allied-offense mergers and by ineffective assistance of counsel; the court affirmed the resentencing and denied relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court should have held merger/hearing on allied offenses before resentencing	Williams (State) argues merger issues were not resolved on remand.	Williams argues resentencing must address allied-offense merger prior to sentencing.	Issue barred; merger issues should have been raised on direct appeal, not at resentencing.
Whether Williams received ineffective assistance of counsel	Williams claims trial counsel failed to object and raise relevant issues.	Williams asserts ineffective assistance for not pursuing certain instructions and experts.	Issue barred by res judicata; arguments were or could have been raised on direct appeal.

State v. Saxon, 109 Ohio St.3d 176 (2006) (res judicata bars reraising issues that could have been raised on direct appeal)