State v. Ayers, 2013 Ohio 4234

David L. Ayers was indicted for violating a protection order (R.C. 2919.27(A)(1)) on July 23, 2012.
At indictment and throughout the case he was already serving a three‑year prison sentence from an unrelated Montgomery County conviction (Case No. 2011‑CR‑1478).
At a bench proceeding on October 17, 2012 Ayers pleaded guilty in exchange for a 12‑month sentence to run concurrently with his existing three‑year sentence.
The trial court awarded Ayers 15 days of jail credit; Ayers objected, arguing he was entitled to additional credit for being held in lieu of bond since July 23, 2012.
Ayers requested a hearing on jail‑credit; the trial court declined because the record showed he was serving time for a separate conviction for the entire period.
Ayers appealed, arguing the court violated his due‑process rights by failing to hold a hearing once he objected to the jail‑credit calculation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court must hold a hearing on jail‑credit after defendant objects	State: No hearing required where record contains necessary facts showing confinement was for a separate offense	Ayers: Once he objected, due process required a hearing and State must prove he wasn’t entitled to additional credit	Court held no hearing required because all facts needed to compute credit were in the record and he was serving time for a separate offense

State ex rel. Rankin v. Ohio Adult Parole Auth., 98 Ohio St.3d 476 (2003) (trial court makes factual determination of days of confinement for jail‑credit; delayed determinations require notice and opportunity to be heard)
State ex rel. Jones v. O'Connor, 84 Ohio St.3d 426 (1999) (errors in trial‑court jail‑credit findings may be raised on direct appeal)