State v. Quarterman, 2014 Ohio 5796

In Nov. 2011, Allen Quarterman pleaded guilty to one count each of burglary and domestic violence and was sentenced to four years of community control (probation).
Probation conditions included a no-contact order, regular drug testing, verifiable employment, and completion of an inpatient drug-treatment program.
Quarterman completed the inpatient program but repeatedly violated other probation terms (contacting victims, positive drug tests, electronic-monitor violations).
After multiple probation-violation hearings and continuances, the court revoked probation and sentenced Quarterman to 18 months in prison, initially awarding 135 days jail-time credit (journal entry dated July 8, 2013).
Quarterman moved for additional jail-time credit (seeking 274 days, including 62 days in inpatient rehab). The trial court granted seven additional days (total 142 days) but denied credit for inpatient treatment.
Quarterman appealed; the appellate court reconsidered sua sponte and affirmed, holding the appeal moot because Quarterman had been released from prison, but discussed statutory changes affecting jail-time-credit review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Quarterman was entitled to jail-time credit for time spent in an inpatient drug-rehab facility required by probation	Quarterman: the 62 days in inpatient rehab were a condition of probation, so he should receive credit toward his prison sentence	State/Trial Ct.: denied credit for inpatient treatment; awarded 142 days total jail-time credit (denying the 62 days)	Appeal dismissed as moot because Quarterman was released; court affirmed trial court's judgment and declined to grant credit on appeal

State ex rel. Gordon v. Murphy, 112 Ohio St.3d 329, 2006-Ohio-6572, 859 N.E.2d 928 (Ohio 2006) (release from custody can render an appeal regarding jail-time credit moot)