State v. Myers, 2021 Ohio 1037

Marvin E. Myers was arrested in April 2014 and later indicted in multiple Franklin County cases, including 14CR-1991 (failure to notify change of address) and 17CR-808 (sexual offenses arising from alleged conduct in December 2014).
Myers remained in custody through various transports and continuances; he pled guilty in both cases on September 10, 2018.
The trial court sentenced Myers on September 11, 2018, awarding 1,027 days of jail-time credit in each case and imposing concurrent and consecutive terms as to counts.
Myers filed multiple pro se motions seeking additional jail-time credit (claiming hundreds more days), attacking the trial court’s calculation.
The trial court denied the third (successive) motion as barred by res judicata; this appeal challenges that denial and contends the court failed to consider the merits and violated due process and related statutory provisions.
The Tenth District affirmed, holding successive post-sentence motions for jail-time credit are barred by res judicata where the issue was or could have been raised earlier, and therefore Myers’s third motion was properly denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether res judicata bars a successive post-sentence motion for additional jail-time credit	State: Res judicata applies to successive motions; Myers already litigated/appealed the credit issue	Myers: Trial court wrongly denied consideration of additional credit; due process violated	Court: Res judicata bars successive motions here; denial affirmed
Whether the trial court abused discretion by not considering merits of the third motion (due process/statutory claim)	State: Trial court properly applied res judicata and need not reach merits of a successive motion	Myers: Court must consider merits under R.C. 2929.19 statutory framework and federal due process	Court: Because res judicata bars this successive motion, merits review was unnecessary and claims are moot
Whether prior appellate ruling forecloses further collateral attempts to increase jail-time credit	State: Prior appeal and intervening denial established final adjudication of credit; later motions are repetitive	Myers: Subsequent filings raise different calculations and evidence entitling him to more days	Held: Prior adjudication prevented relitigation; defendant failed to show entitlement through the record, so successive filings are barred

State v. Thompson, 147 Ohio St.3d 29 (2016) (discusses prior rule that jail-time credit errors generally had to be raised on direct appeal and the limits on collateral challenges)