State v. Dearmond, 2022 Ohio 3252

Marcus N. Dearmond was indicted for third-degree robbery on Feb. 17, 2021; an arrest warrant was served and he remained in custody beginning Sept. 4, 2021.
Dearmond pleaded guilty on Jan. 24, 2022 (no plea agreement); a presentence investigation was ordered.
At sentencing on Feb. 14, 2022 the court imposed 36 months' imprisonment and stated Dearmond would "receive credit for time spent in the Clark County jail."
The written judgment awarded jail-time credit “from September 5, 2021 until conveyance to ODRC,” but did not state the total number of days of credit and included conveyance time.
The State conceded error on appeal. The Second District reversed in part and remanded for the trial court to specify the total number of days of jail-time credit (through the sentencing date, excluding conveyance); the remainder of the sentence was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to determine and include the total number of days of pre-sentence jail-time credit in the sentencing entry	State conceded error and asked for remand so the trial court can determine proper credit	Dearmond argued the court failed to specify total days and improperly included conveyance time, denying proper calculation and opportunity to be heard	Court sustained error, reversed in part, and remanded for the court to specify total days of credit up to and including the sentencing date (excluding conveyance); otherwise affirmed

State v. Fugate, 117 Ohio St.3d 261 (2008) (recognizes R.C. 2967.191 principle that defendants receive credit for confinement related to the offense)
State v. Thompson, 147 Ohio St.3d 29 (2016) (trial court must determine, notify offender of, and include in the sentencing entry the total number of days of pre-sentence confinement)