State v. Perkins, 2019 Ohio 2288

Perkins was arrested after a car crash (Aug 2016), posted bond, later indicted in two separate Lake County cases: 16-CR-000846 (drug charges) and 16-CR-000928 (vehicular assault/DUI related to the crash).
He was jailed on multiple occasions (Aug 1–23, 2016; Oct 5–7, 2016; Jan 20–Apr 13, 2017; Apr 13–May 30, 2017) after bond revocations and pending proceedings.
Sentences: in 16-CR-000846, two consecutive 10-month terms (total 20 months) with 86 days credit; in 16-CR-000928, five years + six months concurrent with the 16-CR-000846 sentence with 138 days credit.
Perkins moved pro se for additional jail-time credit (claimed 224 days), arguing the aggregate days should be applied to each concurrent term; trial court denied the motion.
He appealed the denial, challenging the calculation and relying on Fugate and Caccamo principles concerning credit for days served while detained on pending charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper calculation and allocation of jail-time credit for overlapping periods and concurrent sentences	Perkins: aggregate days (224) should be credited across concurrent sentences; trial court erred in denying additional credit	State/Trial court: credit must be tied to confinement "arising out of" each offense; overlapping period credited to both cases but some periods related only to a single case; later incarceration while serving an earlier-imposed sentence is not creditable to the earlier sentence	Court affirmed: trial court's allocation (86 days in 16-CR-000846; 138 days in 16-CR-000928) was correct; Perkins not entitled to additional credit; some contested principles (crediting days after an earlier sentence begins) noted but not raised on cross-appeal

State v. Fugate, 117 Ohio St.3d 261 (2008) (Equal Protection requires jail-time credit be applied to each concurrent term for confinement arising from pending charges)
State v. Marcum, 146 Ohio St.3d 516 (2016) (standards governing appellate review of criminal-sentencing matters)