State v. Jama, 2018 Ohio 1274

Defendant Shamso Jama was convicted of aggravated possession of drugs and sentenced to a two-year mandatory term; enforcement of the sentence was delayed while she remained free on appeal.
After failing to report for enforcement following unsuccessful appeals, the trial court issued a capias and declared Jama an absconder; she entered Canada in December 2013.
Canadian authorities detained Jama from November 10, 2014 to February 17, 2016; she was returned to Ohio custody and ODRC credited her with 52 days of jail-time in March 2016.
Jama moved under R.C. 2929.19(B)(2)(g)(iii) for an additional 446 days’ credit for time spent in Canadian immigration custody; the trial court granted the motion on August 3, 2017.
The State appealed and obtained a stay; during the appeal Jama completed her two-year sentence and was released from ODRC custody, without benefiting from the additional 446 days awarded by the trial court.
The parties filed supplemental briefs on whether Jama’s release rendered the appeal moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is moot after Jama’s release	Appeal not moot because the trial-court credit might give Jama a future benefit; if moot, court should vacate the trial-court order to prevent future benefit	Appeal moot because Jama completed her sentence and cannot now obtain relief from the additional jail-time credit	Appeal dismissed as moot; no vacatur ordered
Whether Jama was entitled to credit for time in Canadian immigration custody while an absconder	Credit improper because Jama absconded and detention was due to her efforts in Canada, not related to the Ohio sentence	Credit proper under R.C. framework; trial court exercised discretion to award credit	Court did not reach the merits because the appeal was moot
Whether trial court erred by not holding an R.C. 2929.19(B)(2)(g)(ii) hearing	Trial court abused discretion by failing to hold required hearing	Any hearing error is moot given completion of sentence	Not addressed on merits due to mootness
Whether res judicata or other preclusion bars the credit motion	Trial court should have applied res judicata to deny credit	Res judicata inapplicable; trial court rightly considered motion	Not addressed on merits due to mootness

James A. Keller, Inc. v. Flaherty, 74 Ohio App.3d 788 (Ohio App. 1991) (mootness doctrine and limits on courts answering moot questions)
Tschantz v. Ferguson, 57 Ohio St.3d 131 (Ohio 1991) (no actual controversy where outside event renders case moot)
Franchise Developers, Inc. v. Cincinnati, 30 Ohio St.3d 28 (Ohio 1987) (exception for matters of great public interest)
Spencer v. Kemna, 523 U.S. 1 (U.S. 1998) (limitations on the capable-of-repetition-yet-evading-review exception)
Larsen v. State, 92 Ohio St.3d 69 (Ohio 2001) (discussion of mootness and repetition doctrine)
State ex rel. Gordon v. Murphy, 112 Ohio St.3d 329 (Ohio 2006) (no reasonable expectation of repeated action defeats repetition exception)
State ex rel. Brown v. Ohio Dept. of Rehab. & Corr., 139 Ohio St.3d 433 (Ohio 2014) (jail-time credit claims become moot upon completion of sentence)
Crase v. Bradshaw, 108 Ohio St.3d 212 (Ohio 2006) (same)
State v. Golston, 71 Ohio St.3d 224 (Ohio 1994) (felony-conviction appeals survive satisfaction only when conviction itself is challenged)
Arizonans for Official English v. Arizona, 520 U.S. 43 (U.S. 1997) (vacatur as equitable remedy in moot federal appeals)
State v. McGettrick, 31 Ohio St.3d 138 (Ohio 1987) (vacatur/dismissal guidance when appellant dies during appeal)