Lynch v. Bradley
2017 Ohio 1083
Ohio Ct. App.2017Background
- Petitioner David S. Lynch was sentenced in January 2006 to an aggregate 12-year prison term for involuntary manslaughter and aggravated robbery.
- Lynch claims he was entitled to 863 days of jail-time credit that the trial court failed to apply, meaning his maximum release date should have been August 2015 rather than January 9, 2018.
- Lynch previously filed a 2014 motion to correct sentence and a 2015 mandamus action in the Tenth District, both unsuccessful; the appellate court denied relief because the rule he relied on (State v. Fugate) was not retroactive to his final conviction.
- Lynch filed a habeas corpus petition seeking immediate release based on the alleged misapplication of jail-time credit.
- Respondent (Warden Charles Bradley) moved to dismiss under Civ.R. 12(B)(6), arguing habeas corpus is not the proper remedy to challenge jail-time credit when an adequate remedy on the record exists.
- The Fourth District granted the motion to dismiss, holding habeas corpus does not lie where the petitioner had adequate remedies (appeal or motion for jail-time credit).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether habeas corpus lies to challenge calculation/apply of jail-time credit | Lynch: trial court failed to apply 863 days of jail-time credit; thus his maximum sentence expired in 2015 and he is unlawfully confined | Respondent: habeas corpus cannot be used to challenge jail-time credit because Lynch had adequate remedies (appeal/motion) and already pursued them | Habeas corpus does not lie to challenge jail-time-credit calculations when an adequate remedy by appeal or motion exists; petition dismissed |
Key Cases Cited
- State v. Fugate, 117 Ohio St.3d 261 (2008) (holds trial court must apply jail-time credit to all prison terms imposed)
- Johnson v. Crutchfield, 140 Ohio St.3d 485 (2014) (habeas corpus does not lie to challenge jail-time credit when an adequate remedy by appeal exists)
- State ex rel. Williams v. McGinty, 129 Ohio St.3d 275 (2011) (a motion for jail-time credit is an adequate remedy to challenge credit calculations)