State v. Bradshaw, 2014 Ohio 3148

Defendant Dallas Bradshaw admitted violating community-control conditions; trial court revoked supervision and sentenced him to 30 months in prison.
The sentencing entry credited Bradshaw with 55 days "time served" plus additional "future custody days" while awaiting transport; the trial court later indicated he had 91 days total credit.
Bradshaw was represented by counsel at sentencing and did not file a direct appeal from the sentencing entry.
Instead, he filed a post-sentencing motion seeking additional jail-time credit (including 168 days for GPS-monitored home confinement); the trial court denied the motion.
On appeal, Bradshaw argued the court miscalculated credit and improperly refused credit for GPS home confinement time; he did not invoke the amended R.C. 2929.119(B)(2)(g)(iii) provision before the trial court or on appeal.
The appellate court affirmed, holding Bradshaw’s claims were barred by res judicata because he could have raised them on direct appeal and they involve substantive legal determinations, not clerical error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bradshaw was entitled to additional jail-time credit	State: trial court properly calculated and applied available credit	Bradshaw: trial court miscalculated and failed to award 168 days for GPS-monitored home confinement	Court: barred by res judicata; claim could have been raised on direct appeal and involves substantive legal questions, so motion denied and judgment affirmed

Stammco, L.L.C. v. United Tel. Co. of Ohio, 994 N.E.2d 408 (Ohio 2013) (appellate court need not reverse a correct judgment simply because trial court relied on erroneous reasons)