State v. Bingham, 2021 Ohio 4102

Alfred J. Bingham was indicted in Champaign County for aggravated possession of drugs; additional counts and a failure-to-appear amendment followed; multiple capias and bond orders were issued between Feb–Aug 2020.
Bingham was incarcerated in the Montgomery County Jail at various times while facing both Montgomery and Champaign County charges; he was transported between jails for hearings and bond proceedings.
On August 7, 2020, the Champaign County court suspended Bingham’s personal-recognizance bond and issued a capias; Bingham remained jailed in Montgomery County from August 7 through October 29, 2020, and Montgomery County later credited him for that period.
Montgomery County sentenced Bingham on October 29, 2020, to nine months and awarded 104 days’ credit for time served; Bingham did not post bond in that case and remained incarcerated.
On January 26, 2021, Bingham was transported to Champaign County, pled guilty there, and the court sentenced him to 11 months, awarded only 12 days’ jail-time credit in the Champaign case, ordered the Champaign sentence to run concurrently with Montgomery, and revoked his PR bond.
Bingham appealed, arguing he was entitled to an additional 84 days’ jail-time credit (Aug. 7–Oct. 29, 2020) in the Champaign County sentence; the trial court denied that relief noting his Champaign bond was not revoked until Jan. 26, 2021, and that Montgomery had already credited the days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bingham was entitled to 84 additional days of jail-time credit (Aug 7–Oct 29, 2020) on his Champaign County sentence	State/Champaign court: days were not creditable in Champaign because Bingham’s Champaign bond was not revoked until Jan 26, 2021, and Montgomery already credited those days	Bingham: he was confined arising out of the Champaign offense from Aug 7, 2020 and thus entitled to credit for those days	Court: affirmed — Champaign court did not err; those days were credited in Montgomery and Champaign bond revocation occurred later, so no additional Champaign credit was due

State v. Fugate, 117 Ohio St.3d 261 (Ohio 2008) (recognizing R.C. 2967.191 implements equal-protection right to credit for prior incarceration)
State ex rel. Rankin v. Ohio Adult Parole Auth., 98 Ohio St.3d 476 (Ohio 2003) (trial court makes factual determination of number of days of confinement entitled to credit)