2020 Ohio 1561
Ohio Ct. App.2020Background
- Mason was arrested 9/29/2018 for grand theft of a motor vehicle and spent 5 days in Lake County Jail before release.
- Lake County indicted Mason 12/10/2018; a warrant issued after the sheriff could not serve the summons.
- On 7/12/2019 Lake County learned Mason was serving an 8‑month Cuyahoga County sentence; he was conveyed to Lake County, arraigned, and given OR bond but remained in custody due to the Cuyahoga sentence.
- Mason pled guilty 9/11/2019 to one count of grand theft (R.C. 2913.02(A)(2)) and received an 8‑month Lake County sentence to run consecutive to the Cuyahoga sentence; the court awarded 5 days' credit for his 2018 confinement.
- Mason moved for an additional 101 days of jail‑time credit for the period he was held in Lake County after arraignment; the trial court denied the motion because that confinement related to the unrelated Cuyahoga sentence and the Lake County sentence was ordered consecutive.
- Mason appealed, arguing the denial violated his constitutional rights; the appellate court affirmed the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mason is entitled to 101 additional days of jail‑time credit for post‑arraignment detention in Lake County | State: the detention was for an unrelated Cuyahoga sentence and the Lake County term runs consecutive, so credit is not due | Mason: the time detained following arraignment should be credited to his Lake County sentence | Affirmed: credit denied; only confinement related to the offense for which convicted counts toward that sentence, and unrelated detention is not creditable |
Key Cases Cited
- State v. Fugate, 117 Ohio St.3d 261 (2008) (jail‑time credit reduces the length of the prison term and is applied to the sentence to which it pertains)
- State v. Cupp, 156 Ohio St.3d 207 (2018) (an offender is entitled only to credit for time incarcerated on the offense for which he was convicted)
