State v. Nixon, 2019 Ohio 4322

David A. Nixon pleaded guilty (Feb. 2017) to one count of domestic violence and one count of violating a protection order; the two cases were consolidated for sentencing.
Nixon received judicial release, which was later revoked; the trial court entered a nunc pro tunc sentencing entry that this court later vacated for making required consecutive-sentence findings via nunc pro tunc.
Nixon filed a motion for jail-time credit (Feb. 26, 2019), claiming entitlement to 172 days credit and seeking immediate release; the trial court denied the motion (Mar. 12, 2019).
Nixon appealed the denial; contemporaneously, the Ohio DRC records show Nixon was released from prison on Aug. 13, 2019 and placed under Adult Parole Authority supervision.
The court held that because Nixon had already completed his prison term, the jail-time-credit claim was moot and no live remedy remained.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying jail-time credit and whether Nixon is entitled to immediate release based on 172 days credit	The State argued the appeal is moot because Nixon already was released from prison; no live controversy remains	Nixon argued the court miscalculated and failed to credit 172 days, causing him to serve more than his sentence and entitling him to immediate release	Appeal dismissed as moot; completion of sentence forecloses relief on jail-time-credit claim

State ex rel. Brown v. Ohio Dept. of Rehab. & Corr., 12 N.E.3d 1187 (2014) (extrinsic evidence may prove an event that renders a case moot)
Pewitt v. Lorain Correctional Inst., 597 N.E.2d 92 (1992) (same principle regarding mootness proof)
State ex rel. Gordon v. Murphy, 859 N.E.2d 928 (2006) (completion of sentence moots challenges to jail-time calculation)
State ex rel. Compton v. Sutula, 968 N.E.2d 476 (2012) (no available remedy after sentence completion; jail-credit claims become moot)