State v. Lutz, 2017 Ohio 4077

Ronald Lutz was convicted by juries in three interrelated Cuyahoga County cases (CR-01-403228-A, CR-01-404605-A, CR-01-405399-A) and sentenced in August 2001 with an entry stating he was to "receive credit for time served."
Lutz filed a post-sentencing motion (Nov. 16, 2016) seeking jail-time credit for confinement from Feb. 1, 2001 through Aug. 31, 2001 (totaling 212 days), including: Feb. 1–7, 2001 in Lakewood city jail; county jail confinement through Aug. 31, 2001; and Apr. 19–May 17, 2001 at Northcoast Behavioral Center for a court-ordered psychiatric evaluation.
The trial court granted jail-time credit but awarded only 177 days, excluding the Lakewood jail days and the Northcoast evaluation period.
The State conceded error in the trial court’s calculation (arguing for 211 days), and Lutz appealed the 177-day award.
The appellate court reviewed statutory authority for crediting confinement (R.C. 2967.191 and R.C. 2948.38(I)) and relevant precedent construing "confinement" to include institutional stays where a person is not free to come and go.
The court held the correct total was 212 days and reversed and remanded with instructions to credit Lutz with 212 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lutz is entitled to jail-time credit for all confinement from Feb. 1–Aug. 31, 2001, including time in Lakewood city jail and a court-ordered psychiatric evaluation at Northcoast	State concedes trial court miscalculated; suggests 211 days	Lutz contends he is entitled to 212 days (Feb. 1–Aug. 31, 2001), including Lakewood and Northcoast periods	Court held Lutz is entitled to 212 days of jail-time credit and reversed the 177-day award

State v. Napier, 93 Ohio St.3d 646 (2001) ("Confinement" includes stays in institutions or programs where the person is not free to come and go)