State v. Bailey, 2016 Ohio 7249

David Bailey was arrested Sept. 30, 2010 and jailed on bond; charged in separate cases with felonious assault (10CR236) and with child endangering/illegal manufacture (10CR221).
Bailey pleaded guilty to a reduced misdemeanor assault (10CR236) on Jan. 10, 2011 and received 180 days’ incarceration with jail-time credit beginning Oct. 1, 2010.
On Feb. 10, 2011 a jury convicted Bailey of four counts of child endangering (10CR221); those convictions were later affirmed on direct appeal.
In Dec. 2015 Bailey moved for additional jail-time credit in the child-endangering case (10CR221), claiming he was entitled to credit for pretrial confinement; the trial court denied the motion on Jan. 4, 2016, finding the credited time had already been applied to the unrelated misdemeanor assault case.
Bailey appealed, arguing the denial violated due process and equal protection and that he was entitled to jail-time credit under R.C. 2967.191; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bailey is entitled to additional jail-time credit on his child-endangering sentences for pretrial confinement that was credited to a separate misdemeanor sentence	Bailey: pretrial confinement (Oct. 1, 2010 onward) should be credited to his felony sentences under R.C. 2967.191 and Fugate	State: the credited time was already applied to an unrelated misdemeanor sentence; R.C. 2967.191 does not permit credit for time served on separate, unrelated offenses	Court: Affirmed denial; jail-time credit already applied to unrelated assault case, so no additional credit on the child-endangering convictions

State v. Fugate, 117 Ohio St.3d 261 (2008) (Equal Protection principle requires jail-time credit for pretrial confinement when inability to make bail causes confinement)
State v. Copas, 49 N.E.3d 755 (4th Dist. 2015) (post‑S.B. 3, courts have jurisdiction to correct any jail‑time credit error; but R.C. 2967.191 does not mandate credit for confinement on unrelated convictions)