State v. Miller, 2020 Ohio 745

Miller was originally convicted in Scioto County (2011) for child endangerment and sentenced to four years; he received judicial release in 2013 and was placed on five years of community control.
While on community control, Miller was arrested in Pike County on February 27, 2018 for domestic violence/child endangerment; Scioto County issued an order of arrest March 1, 2018.
Records show Miller was in Pike County custody from Feb. 27, 2018 to May 28, 2018 and (per Miller) was transported to Scioto County June 1, 2018; he remained in Scioto custody until an August 3, 2018 revocation hearing.
On August 6, 2018 the Scioto trial court revoked Miller’s community control and imposed a 48-month prison term, awarding 64 days jail-time credit (dates not expressly listed).
Miller filed a motion seeking additional jail-time credit (arguing he was entitled to a total of 155 days — i.e., roughly 91–94 additional days for the Pike County custody period) because the Pike conviction served as the basis for the Scioto revocation; the trial court denied the motion.
The appellate court affirmed, concluding the additional Pike County time was custody for separate, unrelated offenses and therefore not creditable to the Scioto sentence under controlling law and statutes.

Issue	Plaintiff's Argument (Miller)	Defendant's Argument (State)	Held
Whether time Miller served in Pike County on separate charges must be credited against the 48‑month Scioto sentence for community‑control revocation	Pike custody was related to the revocation (the Pike conviction provided the basis for Scioto’s action), so those days must be credited under R.C. 2967.191 and equal‑protection principles	Time in Pike County was confinement for separate, unrelated offenses in another jurisdiction and therefore is not creditable to the Scioto sentence	Affirmed: denial of additional credit upheld; no competent evidence showed the Pike custody “arose out of” the offense for which Miller was sentenced in Scioto, so additional credit was improper

State v. Fugate, 883 N.E.2d 440 (Ohio 2009) (explaining equal‑protection rationale for jail‑time credit)
State v. Thompson, 59 N.E.3d 1264 (Ohio 2016) (sentencing court has continuing jurisdiction to correct jail‑time credit errors)
State v. Moore, 67 N.E.3d 68 (Ohio App. 2016) (convictions in another county that merely provided part of the basis for a probation violation do not create a relationship requiring credit)
State ex rel. Croake v. Trumbull County Sheriff, 587 N.E.2d 978 (Ohio App. 1990) (time served in another jurisdiction for unrelated offenses is not creditable)