State v. Elam

The question certified for our review is whether, under R.C. 2929.41(E), there exists an aggregate minimum term of incarceration for consecutive multiple sentences for offenses that have been imposed consecutively to a life sentence for aggravated murder.

R.C. 2929.41(B) allows the imposition of consecutive terms of incarceration in several situations, including “[w]hen the trial court specifies” that they are to be served consecutively. R.C. 2929.41(B)(1). R.C. 2929.41(E) limits the trial court’s discretion to impose consecutive sentences, and provides in relevant part:

“Consecutive terms of…