State v. Johnson, 2021 Ohio 1629

Ronald G. Johnson was arrested July 11, 2005 and transferred to ODRC custody July 12, 2005; he pleaded guilty in Fayette County on March 28, 2006 and received an aggregate 3-year sentence consecutive to another sentence. The sentencing entry awarded two days of jail-time credit.
Johnson repeatedly sought additional pretrial/jail-time credit for the period between July 12, 2005 and March 28, 2006 (initially claiming 261 days, later 212 days).
He filed multiple post‑sentence motions (2011, Oct. 2012, Nov. 2012, and June 4, 2020) seeking additional credit; earlier motions were denied and not appealed.
The trial court denied the June 4, 2020 motion on June 9, 2020. Johnson appealed; the state did not file a brief, so the appellate court accepted Johnson’s factual statement under App.R. 18(C).
The Twelfth District held the trial court lacked jurisdiction to grant relief under R.C. 2929.19(B)(2)(g)(iii) because Johnson failed to produce evidence that the jail‑credit issue was not raised at sentencing; alternatively, his successive motion was barred by res judicata. The court modified the trial-court entry to dismiss the June 4, 2020 motion for lack of jurisdiction and affirmed as modified.

Issue	Plaintiff's Argument (Johnson)	Defendant's Argument (State)	Held
Whether the trial court erred in denying 212 days of jail‑time credit	Johnson: entitled to 212 days credit for pretrial confinement (July 12, 2005–Mar 28, 2006) and trial court plain‑erred in ignoring his supporting documents	State: prior rulings resolved credit; Johnson failed to show the error was not raised at sentencing and earlier motions were denied and not appealed	Court: No jurisdiction under R.C. 2929.19(B)(2)(g)(iii) because Johnson did not show the issue was not raised at sentencing; motion dismissed
Whether res judicata bars Johnson’s successive jail‑credit motion	Johnson: his motion raises a live credit computation error warranting correction	State: prior final rulings on the same claim (two denials) preclude relitigation; successive motions barred by res judicata	Court: Even if jurisdiction existed, res judicata would bar the successive motion because earlier motions were denied and not appealed

State v. Fugate, 117 Ohio St.3d 261 (Ohio 2008) (equal‑protection and statutory requirement that pretrial incarceration due to indigency be credited to sentence)
State v. Thompson, 147 Ohio St.3d 1 (Ohio 2016) (trial court retains sole jurisdiction to correct jail‑time credit not previously raised at sentencing)