State v. Reeves
2017 Ohio 9139
| Ohio Ct. App. | 2017Background
- William Reeves had multiple cases spanning 2008–2013 involving community-control violations and new indictments; he was ultimately sentenced in 2013 to concurrent terms totaling eight years.
- At sentencing the trial court awarded an aggregate 288 days of jail/CBCF credit across five separate cases rather than specifying credit per case.
- Reeves later filed motions in each case seeking recalculation of jail-time credit, an evidentiary hearing, and appointment of counsel. The trial court granted four additional days in one old case but denied additional credit in the other four and denied the hearing and counsel requests.
- Reeves appealed all five denials; this Court consolidated the appeals. He raised six assignments of error, challenging the aggregate credit, asserting he was entitled to specific or cumulative credits, and claiming denial of a hearing and counsel.
- The Court held parts of the appeals moot because Reeves had already completed the sentences in three cases, sustained two assignments of error because the trial court failed to specify jail-credit allocations for two cases, and overruled the remainder.
Issues
| Issue | Reeves' Argument | State's Argument | Held |
|---|---|---|---|
| Whether trial court erred by awarding aggregate 288 days credit instead of specifying credit for Case No. 2012-04-0938 (73 days) | Reeves: court must award 73 days credit to that individual case | State: aggregate credit across concurrent sentences is permissible / no additional credit due | Court: Reversed and remanded — trial court must calculate and state individual jail-time credit for that case |
| Whether trial court erred by awarding aggregate 288 days credit instead of specifying credit for Case No. 2013-03-0710 (73 days) | Reeves: court must award 73 days credit to that individual case | State: aggregate credit across concurrent sentences is permissible / no additional credit due | Court: Reversed and remanded — trial court must calculate and state individual jail-time credit for that case |
| Whether Reeves was entitled to additional credit or compounding/consecutive credit in Cases Nos. 2008‑02‑0386, 2009‑07‑2200, 2012‑04‑1076 | Reeves: entitled to additional and/or cumulative credit (argues totals should be larger) | State: sentences were concurrent; credit cannot be compounded across separate offenses | Court: Moot as to these three cases (Reeves already served the sentences); in any event concurrent sentences do not permit compounding credit |
| Whether trial court abused discretion by denying a hearing and appointment of counsel under R.C. 2929.19(B)(2)(g) | Reeves: entitled to a hearing and appointment of counsel to establish credit | State: statute does not require hearings or counsel on post‑sentencing credit motions; court has discretion | Court: Overruled — no mandatory hearing or appointment of counsel for post‑sentencing recalculation motion |
Key Cases Cited
- State v. Fugate, 117 Ohio St.3d 261 (Ohio 2008) (when sentences run concurrently jail-time credit must be applied to each concurrent term)
- State v. Thompson, 147 Ohio St.3d 29 (Ohio 2016) (post‑sentencing motion under R.C. 2929.19(B)(2)(g)(iii) permits the sentencing court, in its discretion, to correct jail‑time credit errors)