State v. Freeman, 2019 Ohio 669

Freeman was indicted for fourth-degree felony Receiving Stolen Property after being stopped driving a 2013 Honda Civic that Germain Honda had received and later determined missing from its lot.
The vehicle had been turned in to Germain on July 14, 2017; Germain took ownership July 17, 2017; Freeman was stopped driving the car on July 18, 2017.
During the stop Freeman gave false identifying information, had no driver’s license, and could not identify or contact the person he claimed loaned the car.
A jury convicted Freeman; at sentencing the trial court noted a lengthy criminal history (at least fifteen felonies dating back to 1969, including related property offenses) and imposed an eighteen-month (maximum) prison term.
Freeman appealed, arguing the maximum sentence was improper and that the trial court failed to award jail-time credit for 64 days spent in custody pretrial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether imposing the maximum (18-month) term for a 4th-degree felony was improper	State: sentence within statutory range and supported by trial court's consideration of R.C. 2929.11/2929.12 factors	Freeman: only one seriousness factor under R.C. 2929.12(B) was checked; community control would be more appropriate	Court: Affirmed. Sentence within statutory range; trial court properly considered recidivism factors and Freeman’s lengthy criminal history, so record supports maximum term.
Whether Freeman was entitled to jail-time credit for pretrial incarceration	State (on appeal): concedes trial court failed to give proper credit and urges remand	Freeman: trial court failed to credit 64 days in custody awaiting trial	Court: Reversed in part and remanded to award appropriate jail-time credit.

State v. Mathis, 109 Ohio St.3d 54 (Ohio 2006) (trial courts must consider R.C. 2929.11 and 2929.12 when exercising sentencing discretion)