State v. Henderson, 2018 Ohio 608

Defendant Delaquan Henderson pled guilty in three cases (2013 CR 1782; 2015 CR 1190; 2016 CR 1039) and received concurrent prison terms in August 2016.
At sentencing the trial court awarded 362 days of jail-time credit (credited across the 2013 and 2015 cases).
Henderson filed multiple pro se motions seeking recalculation of jail-time credit, asserting he actually served 431–482 days and that some days should run across concurrent sentences.
The trial court denied the first motion (Oct. 5, 2016) and later denied a new motion (Apr. 4, 2017); Henderson timely appealed the April 4, 2017 entry.
The State argued res judicata barred Henderson’s later challenges because he failed to appeal the initial denial, and that jail-time credit must be calculated per case.
The appellate court affirmed, holding res judicata bars relitigation of the jail-time-credit calculation and noting Henderson’s 2013 sentence had been fully served so any relief there was moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Henderson is entitled to additional jail-time credit or a recalculation across concurrent sentences	The State: trial-court calculation is correct; credit is case-specific and Henderson’s claims are barred by res judicata; relief in 2013 case is moot	Henderson: he served more days (≈431–482) and those days should have been applied across concurrent sentences; alleged mathematical error	Affirmed trial court. Res judicata bars relitigation of the jail-time-credit calculation; any remedy for 2013 CR 1782 is moot because sentence completed

State v. Perry, 10 Ohio St.2d 175 (1967) (establishes res judicata rule barring relitigation of claims that were or could have been raised on direct appeal)