State v. Adams, 2022 Ohio 1644

Jason P. Adams was indicted in two cases (18 CR 482 and 18 CR 862) for drug offenses and entered guilty pleas in February 2019. Sentences on multiple counts were ordered to run concurrently.
The trial court awarded 88 days of jail-time credit in Case No. 18 CR 482 and recorded that no additional credit would be granted in Case No. 18 CR 862 because credit was granted in Case No. 18 CR 482.
Adams did not timely appeal his convictions or the initial credit ruling.
Adams filed multiple pro se motions seeking correction of jail-time credit (arguing the 88 days should be applied to each concurrent sentence, yielding 176 days total). The trial court denied the first motion on August 12, 2019; later motions were unresolved or denied.
After this Court refused leave for a delayed appeal of the August 12, 2019 entry, the trial court denied Adams’s third motion on January 11, 2022; Adams appealed that denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in denying Adams’s motion to apply jail-time credit to each concurrent sentence	State: Adams’s successive motion is barred by res judicata because the August 12, 2019 denial was a final judgment that he failed to timely appeal	Adams: Under State v. Fugate, jail-time credit must be applied to all concurrent terms; the 88 days should reduce each case (total 176 days)	Court affirmed: res judicata bars Adams’s successive motion; his claim is precluded because he did not timely appeal the initial denial

State v. Fugate, 117 Ohio St.3d 261 (Ohio 2008) (jail-time credit must be applied to all concurrent prison terms)
State v. Copas, 49 N.E.3d 755 (4th Dist. 2015) (trial court retains continuing jurisdiction to correct jail-time credit errors)
State ex rel. Sands v. Culotta, 176 N.E.3d 735 (Ohio 2021) (successive motions for jail-time credit can be barred by res judicata)
Grava v. Parkman Twp., 73 Ohio St.3d 379 (Ohio 1995) (res judicata bars subsequent actions arising from the same transaction)