State v. Quarterman
2014 Ohio 4928
Ohio Ct. App.2014Background
- In Nov. 2011, Allen Quarterman pleaded guilty to one count each of burglary and domestic violence and was sentenced to four years community control with conditions: no-contact with victims, regular drug testing, verifiable employment, and completion of inpatient drug treatment.
- Quarterman completed the inpatient treatment but repeatedly violated other probation terms (contacting victims, positive cocaine tests, electronic monitoring violations).
- After multiple probation-violation hearings and continuances, the trial court revoked probation following a fifth violation and sentenced Quarterman to 18 months imprisonment, awarding 135 days jail-time credit in the July 8, 2013 journal entry.
- Quarterman moved for additional jail-time credit, claiming entitlement to credit for 62 days spent in inpatient drug treatment (a probation condition); the trial court granted seven additional days, bringing the total to 142 days, but denied credit for the inpatient treatment time.
- Quarterman appealed the denial of credit for inpatient treatment time; by the time of appeal he had been released from prison, rendering the appeal moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Quarterman was entitled to jail-time credit for time spent in inpatient drug treatment required by probation | State: denial of credit was proper (court did not expressly argue here but opposed full credit) | Quarterman: inpatient treatment was a probation requirement, so those 62 days qualify as time served and warrant jail-time credit | Appeal dismissed as moot because Quarterman was released; the court did not grant the requested credit |
| Whether the trial court retains jurisdiction post-sentencing to correct jail-time credit errors | State: trial court has limited post-sentencing authority (implicit prior law) | Quarterman: N/A on this point in record | Court explained amended R.C. 2929.19(B)(2)(g)(iii) vests trial courts with continuing jurisdiction to correct any jail-credit error post-sentencing |
| Whether a hearing is required on a postsentence jail-time-credit motion | State: N/A | Quarterman: N/A | Court noted R.C. 2929.19(B)(2)(ii) requires considering parties’ arguments and holding a hearing if requested |
| Mootness of appeal | State: appeal is moot due to release | Quarterman: nevertheless sought relief | Court held appeal moot and overruled the assignment of error |
Key Cases Cited
- None with official reporter citations were cited in the opinion.