State v. Guiterres, 2016 Ohio 5572

George Guiterres pleaded guilty in Feb 2014 to multiple state drug offenses and was sentenced to concurrent prison terms; the court awarded seven days jail-time credit for time between plea and sentencing.
Guiterres sought additional credit (240 days) for the period June 2013–Feb 2014, when he was held in the Trumbull County Jail after transfer from federal custody.
The state opposed credit, arguing those days were attributable to pending federal charges; the trial court denied the first motion on April 20, 2015, finding he already received full credit.
Guiterres filed a second, substantively similar motion (raising a new argument about concurrency with the federal sentence); the trial court denied it on June 9, 2015, using the same reasoning as the first denial.
Guiterres appealed the June 9, 2015 denial (after a delayed-appeal allowance); the appellate court held the credit issue barred by res judicata and also noted the record lacked a sentencing transcript to show whether the credit issue had been previously considered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Guiterres is entitled to 240 days additional jail-time credit for time in county jail pre-conviction	State: no additional credit because those days were attributable to federal custody/pending federal charges	Guiterres: entitled to credit because he received no federal credit for that period and federal judgment ordered concurrent sentences	Denied: res judicata bars review of second motion; alternate procedural bar because no sentencing transcript to show the issue wasn’t previously considered

Fugate v. Ohio, 117 Ohio St.3d 261 (Ohio 2008) (addressing preconviction jail-time credit principles)
State v. Szefcyk, 77 Ohio St.3d 93 (Ohio 1996) (res judicata bars issues or arguments that were or could have been raised previously)