State v. Mohamood, 2018 Ohio 3388

Mohamood was indicted in Dec. 2014 on multiple charges; he pled to a reduced misdemeanor (unauthorized use of a motor vehicle) and one felony count proceeded to community control. Several related cases were resolved at sentencing.
At the Feb. 2016 sentencing, the court allocated 180 days of jail-credit to satisfy a misdemeanor in another case, leaving 75 days credited in case No. 14CR-6626.
After community-control violations, the court revoked and resentenced Mohamood in Mar. 2017 to 36 months in prison on 14CR-6626; the court then found he had 351 days of jail-time credit in that case.
Mohamood later filed motions seeking additional jail-time credit (initially claiming 344 days, then amending to request 139 days) and contending allocation among concurrent sentences was improper.
The trial court denied relief; Mohamood appealed only as to case No. 14CR-6626, arguing the court erred in not applying all jail-time credit to his prison sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by not awarding all jail-time credit on concurrent sentences	State: Mohamood waived any new argument not raised below; trial court did not abuse discretion in denying relief	Mohamood: Court unlawfully allocated 360 days to misdemeanors and failed to apply that credit to his felony prison sentence; his Fugate right to credit was violated	Court: Argument not raised below and thus waived; affirmed denial of additional credit

State v. Fugate, 883 N.E.2d 440 (Ohio 2008) (pretrial confinement credit required under Equal Protection for indigent defendants unable to make bail)