State v. Canty, 2015 Ohio 5241

Curtis Canty pleaded guilty on Sept. 2, 2014 to aggravated robbery and involuntary manslaughter and was sentenced to concurrent five-year prison terms.
At sentencing defense counsel requested 555 days of jail-time credit; the prosecutor stated Canty was arrested Feb. 14, 2013, and the court entered a judgment certifying 555 days of credit that same day.
Canty did not appeal the sentence but later (May 26, 2015) moved to correct jail-time credit, claiming the certified 555 days omitted incarceration from Feb. 14–25, 2013 (time in Illinois and transfer to Franklin County).
The State opposed, arguing Canty failed to show a mathematical error and that res judicata barred relief.
The trial court denied the motion on res judicata grounds; Canty appealed to the Tenth District, which reversed and remanded for recalculation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Canty's post-sentencing motion to correct jail-time credit is barred by res judicata or is cognizable under R.C. 2929.19(B)(2)(g)(iii) when alleging a miscalculation	State: Canty failed to demonstrate a mathematical error and the issue is barred by res judicata because it could have been raised at sentencing	Canty: He alleges the sentencing entry omitted days (Feb. 14–24, 2013) and that the omission is a calculational error not previously raised at sentencing; statute permits later correction	The court held res judicata does not bar Canty because R.C. 2929.19(B)(2)(g)(iii) gives the sentencing court continuing jurisdiction to correct jail-time credit errors not raised at sentencing; remanded to determine proper credit

State v. Fugate, 117 Ohio St.3d 261 (Ohio 2008) (criminal defendants have a right to jail-time credit for pretrial confinement when unable to make bail)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (standard for abuse of discretion review: decision must be unreasonable, arbitrary, or unconscionable)