State v. Fleming (2022)
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State v. Shaw (2025)
In other words, “when one offense is completed prior to the completion of another offense during the defendant’s course of conduct, those offenses are separate acts.” State v. Mooty, 2014-Ohio-733, ¶ 49 (2d Dist.), citing Turner at ¶ 24 . {¶ 58} “ ‘Whether offenses are committed separately often hinges on whether there is a temporal or spatial separateness in the offenses.’ ” State v. Fleming, 2022-Ohio-3158, ¶ 17 (2d Dist.), quoting State v. Vanausdal, 2016-Ohio-7735, ¶ 14 …