State v. Reed (Slip Opinion)
166 N.E.3d 1106
Ohio2020Background
- Eric Reed pleaded guilty to a criminal-gang charge and was placed on five years of community-control sanctions with a stipulated five-year prison term if sanctions were violated.
- Reed was placed on postconviction house arrest and electronic monitoring after violations and later admitted violating community-control terms.
- The trial court revoked community control, imposed a five-year prison sentence, and denied Reed credit for the days spent on house arrest/electronic monitoring.
- The Sixth District Court of Appeals reversed, holding Reed was entitled to jail-time credit for that period.
- The State appealed to the Ohio Supreme Court, which framed the question under R.C. 2967.191(A) (jail-time credit for those sentenced to prison).
- The Ohio Supreme Court reversed the Sixth District, holding the statute grants credit only for confinement in public or private facilities and not for confinement in a personal residence (postconviction house arrest).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Reed) | Held |
|---|---|---|---|
| Whether R.C. 2967.191(A) entitles a prisoner to credit for days spent on postconviction house arrest/electronic monitoring | "Confinement" means custody in a public or private facility; house arrest is not such confinement; court of appeals misapplied R.C. 2921.01(E) | "Confinement" includes house arrest; house arrest/electronic monitoring restrain liberty and can trigger escape prosecution; apply rule of lenity if ambiguous | No. R.C. 2967.191(A) awards credit only for types of confinement that occur in public or private facilities; residence-based house arrest/electronic monitoring do not qualify |
Key Cases Cited
- Jones v. Action Coupling & Equip., Inc., 784 N.E.2d 1172 (Ohio 2003) (apply plain statutory meaning when language is unambiguous)
- Jasinsky v. Potts, 92 N.E.2d 809 (Ohio 1950) (courts must apply plain and obvious statutory language)
- Henley v. Youngstown Bd. of Zoning Appeals, 735 N.E.2d 433 (Ohio 2000) (use ejusdem generis when lists are illustrative)
- Rhodes v. New Philadelphia, 951 N.E.2d 782 (Ohio 2011) (give effect to every statutory word; avoid superfluity)
- State v. Pariag, 998 N.E.2d 401 (Ohio 2013) (appellate statutory-interpretation review is de novo)
- Samantar v. Yousuf, 130 S.Ct. 2278 (U.S. 2010) (use of “including” ordinarily signals an illustrative, not exhaustive, list)