State v. Logan, 2021 Ohio 571

Appellant Jeremy (James) Logan pled guilty on March 14, 2019 to one count of aggravated assault (fourth-degree felony) and was sentenced to six months, to run consecutive to an existing Cuyahoga County sentence.
Logan spent 142 days in the Mahoning County Jail awaiting disposition of the assault charge.
On September 11, 2019 Logan filed a pro se motion seeking 142 days of jail-time credit for that pretrial detention; the State opposed the motion.
The State argued Logan was already serving a sentence in Cuyahoga County (involuntary manslaughter) while the Mahoning charge was pending, so the Mahoning detention did not generate additional credit.
The trial court denied the motion; Logan filed a delayed appeal to this court raising a single assignment of error challenging denial of jail-time credit.
The appellate court affirmed, holding Logan waived the challenge by not bringing a direct appeal from the sentencing entry and, on the merits, was not entitled to credit because his detention arose from a separate criminal sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Logan is entitled to 142 days jail-time credit for time in Mahoning County Jail awaiting disposition	State: No — Logan was already serving a Cuyahoga County sentence during that time, so no additional credit is due	Logan: He spent 142 days awaiting disposition and should receive credit against the Mahoning sentence	Court: Claim waived for failure to appeal sentencing entry; alternatively, meritless — no credit where detention arose from separate offense/sentence

State v. Smith, 71 Ohio App.3d 302 (1992) (a defendant is not entitled to jail-time credit for incarceration attributable to separate and distinct offenses)