State v. Burch

Citations

• 2026 Ohio 777

Syllabus

Defendant's convictions and sentence for, among other crimes, aggravated arson, are affirmed. The trial court was not required to advise defendant regarding the possible merger of offenses for sentencing, and defendant's aggravated arson charges did not merge because the single fire posed a risk to multiple victims. Consecutive sentences were supported by the record despite the defendant's lack of criminal history. Finally, the trial court's amended sentencing order corrected a typographical error and had no effect on issues that were contested at the trial level, meaning it was a permissible nunc pro tunc order despite coming after a notice of appeal.