State v. Phillips, 2016 Ohio 5194

Keith Phillips pleaded guilty (Feb 3, 2010) to felonious assault with a firearm specification and having a weapon while under disability; total prison term 8 years (3-year firearm spec consecutive to 5-year concurrent terms).
Sentencing entry granted 173 days jail-time credit "along with future custody days while Defendant awaits transportation to the appropriate State institution."
Phillips later filed pro se motions: (1) 2014 motion to vacate (treated as untimely postconviction and denied on appeal), and (2) Jan. 5, 2015 motion seeking additional jail-time credit; the trial court denied the 2015 motion (Dec. 1, 2015).
Phillips appealed, arguing the court failed to calculate and include credit for days held after sentencing awaiting transport and 90 days from a separate 2008 case.
The trial court’s entry expressly awarded credit for post-sentencing transport days and ordered concurrent service with the 2008 case; the court found no record evidence Phillips actually was denied the credited days beyond his own assertions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Phillips’s motion for additional jail-time credit is barred by res judicata	State: res judicata bars re-litigation of sentencing issues not raised on direct appeal	Phillips: R.C. 2929.19(B)(2)(g)(iii) allows motions to correct jail-time credit at any time after sentencing	Court: Not barred; continuing jurisdiction under R.C. 2929.19(B)(2)(g)(iii) and Ohio Supreme Court precedent permits review
Whether the trial court failed to award credit for post-sentencing days awaiting transport	State: sentencing entry already granted 173 days plus future transport days; no record evidence of under-crediting	Phillips: trial court failed to include or ensure credit for days after sentencing awaiting transport	Court: Entry expressly granted transport-day credit; Phillips’s bare assertions insufficient to show error
Whether Phillips was denied credit for 90 days in separate 2008 case (2008-CR-754)	State: sentencing entry ordered concurrent service; no record evidence credit was withheld	Phillips: he did not receive credit for the 90 days served on the 2008 case	Court: Concurrent sentence and no record evidence showing credit was not applied; claim unsupported by record
Whether appellant proved entitlement to additional jail-time credit	State: burden on appellant to show error; record does not support	Phillips: asserts he did not receive full credit	Court: Phillips offered only self-serving allegations; motion denied and judgment affirmed

State ex rel. Rankin v. Ohio Adult Parole Auth., 98 Ohio St.3d 476, 786 N.E.2d 1286 (discussing trial court's role in calculating jail-time credit and scope of credit for transport days)