State v. Henry, 2021 Ohio 888

Devon Henry was indicted in Guernsey County on June 11, 2019 for second-degree trafficking in hashish and heroin; forfeiture specifications included. Charges were later reduced to fifth-degree felonies.
Henry was detained in the Mahoning County Jail beginning June 21, 2019 on a federal supervised-release violation/detainer; his Guernsey bond was set as personal recognizance with a proviso about federal hold.
Henry pled guilty to the amended fifth-degree trafficking counts on February 26, 2020. At sentencing the court imposed consecutive terms of 11 months and 9 months (20 months total) and ordered $2,100 forfeited.
Defense sought additional jail-time credit for the period Henry was confined in Mahoning County under the federal detainer, arguing that the detention arose out of the offenses for which he was convicted in Guernsey County.
The trial court awarded 41 days' credit (as of June 18, 2020) for time in county custody on this case and credit for time awaiting transport, but denied credit for the time Henry spent in Mahoning County under federal custody.
Henry appealed, claiming the court erred by denying additional jail-time credit; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether detention on a federal detainer counts as jail-time credit for state sentence	State: Time held on federal detainer is not creditable to the Guernsey County sentence because it was custody under federal authority	Henry: Time in Mahoning County under the federal holder arose out of the offenses charged in Guernsey County and therefore should be credited toward his state sentence	The court held Henry is not entitled to credit for time spent in federal custody; credit was limited to days spent in local custody on the state case and time awaiting transport

State v. Cupp, 124 N.E.3d 811 (Ohio 2018) (time spent in confinement for unrelated cases or awaiting trial on an unrelated case cannot be credited toward another case)