State v. Reeder, 2020 Ohio 5107

Background

Reeder was arrested in Aug. and Dec. 2018 on drug- and related charges; separate indictments arose from contraband found on his person and at a domestic-welfare call. He eventually pled guilty (Apr. 25, 2019) to one count of aggravated possession (5th‑degree) and one count of possession of heroin (4th‑degree); remaining counts were dismissed and agreed forfeitures ordered.
At arraignments the court set bond (a $15,000 bond in the 2018 case and an OR bond in the 2019 case) with written conditions including appearing for court; at the plea hearing the court orally told Reeder to “cooperate fully with the probation department during the presentence investigation.” That oral condition was not separately journalized in a standalone bond‑modification entry.
Reeder completed a PSI questionnaire but missed two scheduled PSI interviews; the PSI was completed from the questionnaire.
At sentencing (May 16, 2019) the trial court imposed concurrent prison terms (12 and 18 months), finding it had discretion under R.C. 2929.13(B)(1)(b)(iii) because Reeder violated a condition of bond by failing to cooperate with the PSI. The court credited jail time in the 2019 case but not in the 2018 case.
On appeal the court held that the orally‑stated PSI cooperation condition was not journalized and thus could not support a prison sentence under R.C. 2929.13(B)(1)(b)(iii); it vacated the prison sentences and converted them to up to five years of community control (deemed completed) and vacated post‑release control. The jail‑credit claim for the 2018 case was held moot because Reeder had already completed his sentence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2929.13(B)(1)(b)(iii) authorized prison because Reeder violated a bond condition by failing to cooperate with the PSI	Reeder violated both original bond terms (appear for court matters) and the plea‑hearing condition to cooperate with the probation department; thus prison was permitted	The additional PSI‑cooperation condition was only stated orally and not journalized; PSI interviews were not "matters before the Court" set by the court, so community control was mandatory	Vacated prison sentences and converted to community control; oral bond condition not enforceable to authorize prison under R.C. 2929.13(B)(1)(b)(iii)
Whether the trial court erred by failing to award jail‑time credit in Case No. 2018‑CR‑764	State: Because sentences run concurrently, jail credit should have been applied to both cases and the proper remedy is remand for correction	Reeder: Trial court violated statutory and equal‑protection entitlements to jail‑credit and should be awarded credit	Overruled as moot — defendant already served his aggregate sentence; no effective relief available

Key Cases Cited

Anders v. California, 386 U.S. 738 (procedural standard for counsel raising frivolous appeal)
State v. Marcum, 146 Ohio St.3d 516 (Ohio standard of appellate review for felony sentences under R.C. 2953.08(G)(2))
State v. Springer, 34 N.E.3d 441 (trial court must give prior notice/journalize bond conditions before relying on them to impose prison under R.C. 2929.13(B)(1)(b)(iii))
State ex rel. Rankin v. Ohio Adult Parole Auth., 98 Ohio St.3d 476 (trial court determines factual jail‑credit entitlement; DRC must apply credit)
State v. Fugate, 117 Ohio St.3d 261 (R.C. 2967.191 implements equal‑protection right to jail‑credit)
Kaine v. Marion Prison Warden, 88 Ohio St.3d 454 (a court speaks through journal entries, not oral pronouncements)
State v. Hampton, 134 Ohio St.3d 447 (same principle regarding journalization of court actions)