State v. Bolen

Citations

• 2025 Ohio 5104

Syllabus

Allied Offenses; Consecutive Sentences; Crim.R. 11 Colloquy; Guilty Plea. In order to impose consecutive sentences, the trial court must make the findings required by R.C. 2929.14(C)(4). Allied offenses of similar import are to merge at sentencing. Merger is not required where offenses are dissimilar in import; were committed separately; or committed with separate animus. In examining a Crim.R. 11 colloquy to determine if a plea was knowingly, voluntarily, and intelligently entered, a reviewing court examines whether (1) the trial court has complied with the relevant provisions of the rule; (2) whether any failure to fully comply with the rule requires a demonstration of prejudice to vacate the plea; (3) whether the defendant has demonstrated prejudice where required for a failure to comply with Crim.R. 11.