State v. Street

Citations

• 2026 Ohio 864

Syllabus

Per Mayle, J., trial court did not commit plain error when it failed to merge convictions of theft of cash and receiving stolen property, a credit card. Although cash and credit card were stolen at same time when defendant took victim's bag, his later use of credit card caused separate harm. For these same reasons, trial counsel was not ineffective for failing to argue merger.