State v. Durant, 2016 Ohio 8173

Charles Daniel Durant pleaded guilty in May 2013 to two counts of fifth-degree felony drug trafficking and entered a drug-court program.
Durant had multiple drug-court violations, was sanctioned (including placement at a corrections center), tested positive for cocaine, and ultimately self-terminated from the program in January 2015.
The trial court sentenced Durant on February 2, 2015 to consecutive 12-month prison terms on each count (24 months total) and suspended his driver’s license for three years.
The court awarded Durant 200 days of jail-time credit in its February 3, 2015 entry.
Durant appealed, arguing (1) the court was required to impose community control under R.C. 2929.13(B)(1) rather than incarceration, and (2) he was entitled to an additional 13 days of jail-time credit (total 213 days).
The state conceded the jail-credit error but defended the prison sentence under the sentencing statutes and Durant’s multiple convictions and drug-court termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2929.13(B)(1) required community control instead of prison for multiple fifth-degree felonies	State: Court may sentence to prison based on seriousness/recidivism factors; drug-court termination justified stricter sanction	Durant: As a first-time felon of fifth degree, statute mandates community control absent an exception; court should pick least restrictive sanction	Court: R.C. 2929.13 community-control presumption does not plainly apply to multiple fifth-degree felonies; drug-court violations and self-termination justified prison; no abuse of discretion—affirmed
Whether trial court erred in jail-time credit calculation	State: concedes mistake and that additional credit is warranted	Durant: Entitled to 213 days (200 awarded + 13 days held awaiting sentencing)	Court: Agreed with parties; modified sentence to add 13 days of credit (total 213)

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