State v. Primack, 2014 Ohio 1771

Jonathan Primack was indicted in Washington County for trafficking (Oxycodone); warrant issued June 2012.
In December 2012 he pled guilty in Tuscarawas County to other drug offenses and began serving a 24‑month prison term on December 11, 2012.
While serving the Tuscarawas sentence, Primack sought disposition of the Washington County charge and later pled guilty there pursuant to a plea agreement.
At sentencing in Washington County the court imposed a 30‑month term to run concurrently with the Tuscarawas sentence and awarded only two days of jail‑time credit.
Primack appealed, arguing he was entitled to credit for the days he spent incarcerated on the Tuscarawas sentence while awaiting disposition of the Washington County charge (about 157 days).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Primack is entitled to jail‑time credit for time incarcerated on an unrelated (Tuscarawas) sentence while awaiting disposition in Washington County	State: trial court correctly calculated credit (implicit)	Primack: should receive credit for pretrial confinement in Washington County while an arrest warrant was active and he could not post bail because he was serving the Tuscarawas sentence	Court: No. R.C. 2967.191 does not allow credit for time served on unrelated offenses even if sentences run concurrently; trial court did not err

Fugate v. Welbaum, 117 Ohio St.3d 261 (Ohio 2008) (holds jail‑time credit must be applied to all concurrent prison terms imposed for charges on which the offender was held; but does not permit credit for time served on unrelated offenses)