State v. Williams

Citations

• 2020 Ohio 1368

Syllabus

KIDNAPPING — EVIDENCE — SENTENCING — FIREARM SPECIFICATIONS — MERGER — COUNSEL: Defendant's conviction for kidnapping and the accompanying firearm specification was not against the weight or the sufficiency of the evidence where the state presented evidence that defendant grabbed the child from the victim's arms and fled from the residence and had a firearm during the commission of the kidnapping and failure-to-comply offenses. The trial court did not err when it declined to merge multiple firearm specifications accompanying convictions for kidnapping and failure to comply: the offenses were not committed as part of the same act or transaction and did not arise from a single criminal adventure, occurring at different locations and times and having been committed with different purposes. Defendant did not receive ineffective assistance of counsel for counsel's failure to adequately communicate the trial strategy or review discovery with defendant where defendant failed to demonstrate a reasonable probability that an alternative strategy would have changed the outcome.