State ex rel. Sands v. Culotta (Slip Opinion), 176 N.E.3d 735

In December 2006 Joseph A. Sands was convicted in Lake County Common Pleas Court and sentenced to an aggregate 20-year term.
Sands filed a motion to correct his jail-time credit; Judge Vincent Culotta entered an order granting additional credit but Sands contended the credited amount remained incorrect.
Sands appealed the trial-court decision on jail-time credit to the Eleventh District and lost; the Ohio Supreme Court declined discretionary review.
On March 23, 2020 Sands filed two mandamus actions in the Eleventh District: one against the county prosecutor (dismissed) and one against Judge Culotta seeking a new sentencing hearing and recalculation of jail-time credit.
The court of appeals dismissed the mandamus complaint against Judge Culotta, interpreting it (erroneously) as seeking dismissal of convictions for alleged perjured testimony and finding an adequate remedy at law; the dismissal operates as an adjudication on the merits.
The Ohio Supreme Court held the court of appeals’ judgment was final and appealable and affirmed the dismissal because mandamus is not the proper remedy for jail-time-credit disputes and the claim was barred by res judicata.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court of appeals' dismissal is a final, appealable order	Sands: judgment is appealable	Culotta/State: dismissal is final	Held: dismissal is final and appealable (res judicata effect)
Whether mandamus can compel recalculation of jail-time credit	Sands: judge must recalculate credit; mandamus appropriate	Culotta/State: mandamus not appropriate; adequate remedies exist	Held: Mandamus is not available for jail-time-credit errors because adequate remedies exist (direct appeal or statutory postsentence motion); claim also barred by res judicata

State ex rel. Scruggs v. Sadler, 97 Ohio St.3d 78 (jurisdictional finality requires R.C. 2505.02 analysis)
State ex rel. Arcadia Acres v. Ohio Dept. of Job & Family Servs., 123 Ohio St.3d 54 (dismissal for failure to state a claim operates as adjudication on the merits)
State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (elements required to obtain writ of mandamus)
State ex rel. Rankin v. Ohio Adult Parole Auth., 98 Ohio St.3d 476 (jail-time-credit issues cognizable on direct appeal)
State ex rel. Jones v. O'Connor, 84 Ohio St.3d 426 (mandamus will not lie against sentencing judge for jail-time-credit disputes)
State v. Thompson, 147 Ohio St.3d 29 (denial of motion for jail-time credit is a final, appealable order)
State ex rel. Natl. Elec. Contrs. Assn. v. Ohio Bur. of Emp. Servs., 83 Ohio St.3d 179 (standard for Civ.R. 12(B)(6) dismissal review)
Alford v. Collins-McGregor Operating Co., 152 Ohio St.3d 303 (12(B)(6) dismissal reviewed de novo)
Salloum v. Falkowski, 151 Ohio St.3d 531 (court will affirm a correct judgment despite erroneous reasons)