State v. Saxon

In State v. Saxon, 109 Ohio St.3d 176, 2006 Ohio 1245, 846 N.E.2d 824, the supreme court specifically rejected the doctrine: "The sentencing-package doctrine has no applicability to Ohio sentencing laws: the sentencing court may not employ the doctrine when sentencing a defendant, and appellate courts may not utilize the doctrine when reviewing a sentence or sentences." Id. at P10. The supreme court stated that the rationale for the doctrine "fails in Ohio where there is no potential for an error in the sentence for one offense to permeate the entire multicount group of sentences;" and that "because Ohio does not 'bundle' sentences, nothing is 'unbundled' when one of several sentences is reversed on appeal." Id. at P8, 15. The court further stated: "Any adoption of the sentencing-package doctrine would dismantle the carefully crafted statutory scheme. No purpose can be served by forcing a sentencing judge to revisit properly imposed, lawful sentences based upon an error in the sentence for a separate offense." Id. at P21.