State v. Cox, 2017 Ohio 2606

Defendant Vernon Lee Cox was convicted of multiple sex offenses against a child and received an aggregate 30-year prison sentence; prior direct and collateral appeals were denied.
Cox sought additional jail-time credit for 306 days he spent on pretrial electronically monitored house arrest (EMHA), arguing its conditions effectively confined him and caused loss of employment.
The Division of Court Services reported Cox properly received 35 days of credit for actual jail time; the trial court denied any additional credit.
Cox moved pro se to the trial court and appealed the denial, relying on R.C. 2929.01(P)(1) and State v. Long.
The court considered whether pretrial EMHA that prevents working qualifies as "confinement or detention" warranting jail-time credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pretrial EMHA that prevents employment qualifies as confinement for jail-time credit	State: pretrial EMHA as condition of bail is not confinement; no additional credit owed	Cox: strict EMHA prevented working and thus should count as confinement deserving 306 days credit	Court: Pretrial EMHA as bail condition does not qualify for jail-time credit; denial affirmed

State v. Long, 82 Ohio App.3d 168 (2d Dist. 1992) (post-conviction EMHA treated as confinement for purposes of an escape charge; distinguishes post-conviction from pretrial EMHA)
State v. Thompson, 59 N.E.3d 1264 (Ohio 2016) (procedural note on final, appealable orders in sentencing context)