State v. Williams

{¶ 1} The issue we address in this case is whether an appellate court should apply a de novo or an abuse-of-discretion standard when reviewing a trial court’s determination of whether a defendant’s offenses should merge pursuant to R.C. 2941.25. We hold that a reviewing court should review the trial court’s R.C. 2941.25 determination de novo.

Factual and Procedural Background

{¶ 2} The alleged victim in this case, J.W., was the eight-year-old niece of defendant-appellee, Jason Williams. On June 22, 2009, Williams and his niece were among a group of people gathered at the home of the victim’s…