State v. Wright, 2018 Ohio 877

Jacqueline Wright was indicted on eight counts of theft for breaking into vehicles and stealing credit cards.
Wright pleaded no contest and was convicted on all eight counts.
The trial court imposed concurrent 10-month terms on counts 1–3, to run consecutively with consecutive 10-month terms on counts 4–8, for an aggregate 60-month sentence.
Counts 1 and 3 arose from the same vehicle break-in and involved two credit cards taken from a single victim (Nicholas Staples).
The trial court acknowledged on the record that some counts were allied offenses of similar import but the final sentence did not merge counts 1 and 3.
The court also imposed consecutive sentences and explained its reasons at sentencing, noting public protection, punishment, Wright’s criminal record, and that she committed crimes while on probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counts 1 and 3 are allied offenses of similar import requiring merger	State conceded counts should merge for allied-offense purposes	Wright argued counts 1 and 3 arose from one event and therefore must merge	Counts 1 and 3 are allied and must be merged; remand for election/sentencing on one count
Whether the trial court satisfied R.C. 2929.14(C)(4) when imposing consecutive sentences	State argued the court made the requisite findings and provided reasons on the record	Wright argued the court failed to make all statutory findings for consecutive sentences	Court held the record supports the required findings; consecutive sentences were proper

State v. Ruff, 34 N.E.3d 892 (Ohio 2015) (sets the allied-offenses-of-similar-import test and directs inquiry into defendant’s conduct)
State v. Underwood, 922 N.E.2d 923 (Ohio 2010) (discusses allied-offense merger principles)
State v. White, 997 N.E.2d 629 (Ohio 2013) (addresses appellate standard for reviewing felony sentences)