State of Ohio v. Tytus Bailey, Case No. 2021-1432
First District Court of Appeals (Hamilton County)

ISSUES:
- Must an appeals court defer to a trial court's discretion not to merge two offenses for sentencing purposes?
- If an offender appeals a trial court's failure to merge two offenses, without objecting in trial court, can an appeals court change the trial court's ruling without finding a "manifest injustice?"