State v. Barnett, 2014 Ohio 3686

Barnett pled guilty in Mahoning C.P. Ct. to carrying a concealed weapon (fourth-degree felony) on Nov. 7, 2012 and was released on his own recognizance pending sentencing.
On Dec. 20, 2012 the C.P. Court imposed community control and ordered Barnett into an in-house CCA program (up to six months); he absconded Apr. 25, 2013; a bench warrant issued and he was arrested May 8, 2013.
At resentencing the parties disputed jail-time credit: the State calculated 232 days total; Barnett sought an additional 62 days, claiming the Mahoning County Court in Boardman erroneously kept him detained from Nov. 7, 2012 to Jan. 8, 2013.
The parties agreed the Boardman charge (nature not in record) was separate and unrelated to the C.P. Court charge.
The trial court declined to award the extra 62 days and sentenced Barnett to 18 months with 232 days’ credit; Barnett appealed the denial of the additional credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Barnett is entitled to an extra 62 days jail-time credit for days he claims he was inadvertently detained by the Boardman Court	Barnett was not being held by the C.P. Court after Nov. 7, 2012; only confinement related to the offense being sentenced is creditable	Barnett was physically incarcerated for those 62 days due to a Boardman court error and should receive credit regardless of which court held him	Court held no; credit only covers confinement "arising out of the offense" being sentenced; time detained on a separate, unrelated case does not mandate credit from the sentencing court

State v. Dawn, 45 Ohio App.2d 43 (1st Dist. 1975) (defendant not entitled to credit for confinement arising from facts separate from current sentence)
State v. Logan, 71 Ohio App.3d 292 (10th Dist. 1991) (incarceration on an unrelated prior conviction during pendency of present case does not entitle defendant to present-case credit)