State v. Dyer, 2022 Ohio 1519

Dyer was indicted Jan. 30, 2020 for tampering with evidence and having a weapon while under disability; he was already incarcerated at that time on prior Mahoning County sentences imposed in 2016–2017.
A removal warrant was issued for his arraignment; bond was deferred because he remained in prison. Three weeks before his scheduled release the court set bond; Dyer was released and posted surety on Aug. 18, 2020.
On June 14, 2021 Dyer pled guilty pursuant to an agreed 12‑month sentence; sentencing occurred the same day and a reporting date was set for July 14, 2021.
Dyer moved for jail‑time credit for the period from indictment to his release from the prior sentences; the trial court awarded one day (the day he posted bond) and denied credit for the rest.
The court found the confinement after indictment was the result of prior unrelated convictions (consecutive drug and disrupting public-service sentences) and that the new charges arose from later discovery of a buried rifle tied to a shooting.
Dyer appealed, arguing the post‑indictment confinement was related to the instant offense (so creditable) or otherwise should be treated as confinement on bond; the appellate court affirmed the trial court.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Dyer)	Held
Whether Dyer is entitled to jail‑time credit for days incarcerated after indictment when incarceration resulted from prior sentences allegedly "related" to the new charges	Dyer was incarcerated on prior, separate convictions; those days did not "arise out of" the offense for which he was sentenced here, so only the day he posted bond is creditable	The post‑indictment confinement should be credited because (1) he was not "held on bond" so confinement should be treated as tied to the indictment, and/or (2) his prior disrupting‑public‑service sentence was related to the instant firearm/tampering charges	Court affirmed: credit only for confinement that "arose out of" the offense being sentenced; confinement on prior unrelated sentences is not creditable (only one day credited)

State v. Cupp, 156 Ohio St.3d 207 (2018) (holding a defendant serving a sentence on an unrelated case is not entitled to jail‑time credit for time held on bond for a different offense)
State v. Fugate, 117 Ohio St.3d 261 (2008) (explaining the equal‑protection foundations and purpose of jail‑time credit statutes)
State ex rel. Rankin v. Mohr, 130 Ohio St.3d 400 (2011) (no entitlement to reduce a sentence by days confined on other crimes while awaiting sentencing)