State v. Blanchard

In State v. Blanchard, Cuyahoga App. No. 90935, 2009 Ohio 1357, the appellant argued that the trial court erred by failing to find that his pandering charges were allied offenses of similar import and merge his convictions for sentencing. Blanchard pled guilty to 15 counts of pandering sexually oriented matter involving a minor. He argued that the photos that were the subject of his charges were taken in quick succession and not separate, distinguishable offenses. In finding that the trial court did not err by failing to merge the pandering charges, the Court held that "the mere fact that the crimes occurred in quick succession does not mean that they were not committed separately or with separate animus." Id. at P12.