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2020 Ohio 1561
Ohio Ct. App.
2020
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Background

  • 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)
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Case Details

Case Name: State v. Mason
Court Name: Ohio Court of Appeals
Date Published: Apr 20, 2020
Citations: 2020 Ohio 1561; 2019-L-168
Docket Number: 2019-L-168
Court Abbreviation: Ohio Ct. App.
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