State v. Quarterman, 2014 Ohio 3925

Quarterman pleaded guilty to burglary and domestic violence in November 2011 and received four years of community control sanctions (probation).
Probation included a no-contact order, drug testing, employment requirements, and inpatient drug treatment; he completed inpatient treatment but violated other terms.
Probation violations included contacting victims, positive cocaine tests, and electronic monitoring violations, leading to multiple continuances and eventual probation revocation.
After a fifth violation, the court revoked probation and sentenced Quarterman to 18 months in prison; the journal entry stated 135 days of jail-time credit.
On August 30, 2013, Quarterman moved for jail-time credit, seeking 274 days; the court granted partial credit totaling 142 days and denied credit for inpatient treatment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Quarterman is entitled to jail-time credit for inpatient treatment days	Quarterman contends he earned 62 days credit for inpatient rehab as a probation requirement.	Quarterman argues the court miscalculated and failed to credit days spent in inpatient treatment.	Res judicata bars review; no entitlement shown on direct appeal; appeal denied.

State v. Fugate, 117 Ohio St.3d 261 (2008) (equal protection; bail-related credit)
State v. Clemons, 2009-Ohio-2726 (8th Dist. Cuyahoga) (burden to show jail-time credit calculation error)
State v. Quunie, 2014-Ohio-1435 (8th Dist. Cuyahoga) (res judicata forecloses raise of issues that could have been raised on direct appeal)
State v. Saxon, 2006-Ohio-1245 (Ohio Supreme Court) (res judicata principle for post-conviction claims)