State v. Moore, 2016 Ohio 3510

David M. Moore pleaded guilty in 2011 to robbery (third-degree) and theft of drugs (fourth-degree); sentenced to concurrent terms including a 4-year term on robbery.
He received judicial release in 2012 and was placed on intensive supervision probation, later extended to July 2015 for nonpayment of fees.
A capias for probation violation was issued by Ashtabula County on September 12, 2014, after Moore failed to comply with probation terms.
Moore was arrested in Lake County in November 2014 on separate forgery and misuse-of-credit-card charges, served approximately nine months there, and was then transported to Ashtabula for the probation matter.
At sentencing on the Ashtabula convictions, the trial court granted Moore 742 days of jail-time credit but denied credit for the nine months served in Lake County because those days were for an unrelated conviction and there was no evidence he was being held there on an Ashtabula holder.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Moore is entitled to jail-time credit for time served in Lake County while an Ashtabula capias was pending	State: Credit is limited to confinement arising from the offense being sentenced; unrelated confinement does not qualify	Moore: If an Ashtabula probation holder existed while he was in Lake County, those days should be credited toward his Ashtabula sentence	Court: Affirmed denial of additional credit — Moore proved 742 days but presented no evidence a holder caused the nine months in Lake County, and those days were for unrelated offenses

(No cited authorities in the opinion have official reporter citations provided in the record before this court.)