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2019 Ohio 3823
Ohio Ct. App.
2019
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Background

  • Richard L. George was indicted in two Medina County cases (18CR0582 and 18CR0738) for two separate third-degree felonies (failure to comply with police). Bonds were set and warrants issued in June and July 2018.
  • George was serving an unrelated prison sentence in Wayne County when Medina issued warrants and ordered removals from other institutions to Medina for court appearances. He was transported to Medina County Jail several times but did not post bond and was returned to the other institutions after hearings.
  • On April 1, 2019, George pleaded guilty in both Medina cases and received consecutive 9‑month sentences in each, with 17 days jail‑time credit in each case; both sentences were ordered consecutive to his Wayne County sentence.
  • On April 11, 2019, George filed pro se motions to correct jail‑time credit, asserting entitlement to roughly 302–304 days credit (including time in a CBCF and time after warrants were placed while he was already incarcerated). The trial court reviewed sheriff’s records and denied the motions.
  • George appealed the denial, arguing the trial court failed to award him the claimed 302 days of jail‑time credit.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the trial court erred in denying George additional jail‑time credit (claimed ~302 days) George: entitled to ~302–304 days because warrants were placed while he was already incarcerated on unrelated charges, he did not post bond, and time in CBCF/county jail should be credited State: trial court acted within its discretion; George’s new timing theory (credit from warrant placement while serving another sentence) was not raised below and is therefore forfeited; jail‑credit determinations are factual and reviewed for abuse of discretion Affirmed. Denial upheld. George forfeited the new argument not raised in his post‑sentence motion; trial court’s denial was within its discretion.

Key Cases Cited

  • None — the opinion primarily cites Ohio appellate slip decisions and statutory provisions; no key authorities with official reporter citations were relied upon.
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Case Details

Case Name: State v. George
Court Name: Ohio Court of Appeals
Date Published: Sep 23, 2019
Citations: 2019 Ohio 3823; 19CA0037-M
Docket Number: 19CA0037-M
Court Abbreviation: Ohio Ct. App.
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    State v. George, 2019 Ohio 3823