State v. Spears, 2014 Ohio 146

Spears was arrested on Nov. 28, 2012 for trespass in an occupied structure (burglary) and arson; he pled guilty to burglary on Jan. 9, 2013 and arson was dismissed.
He was sentenced to three years in prison with 29 days of jail time credit.
During sentencing he sought 28 additional days of jail time credit for a separate misdemeanor (Dec. 12, 2012 to Jan. 9, 2013) served while detained on the felony case.
The trial court agreed in principle but held that prior case law barred credit for time served on a separate misdemeanor.
The court ultimately denied the asserted credit, issuing a judgment of three years with 29 days credit.
Spears appeals, challenging the jail-time credit ruling under R.C. 2967.191.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Spears is entitled to jail-time credit for time served on a separate misdemeanor.	Spears argues R.C. 2967.191 requires credit for any confinement arising from the offense, including time served for unrelated offenses.	Spears alleges the statute requires concurrent credit regardless of unrelated charges.	No; jail-time credit not permitted for time served on a separate offense.

State v. Angi, 2012-Ohio-3840 (Ohio 2012) (equal-protection considerations for prior incarceration credit)
State v. Coyle, 2010-Ohio-2130 (Ohio 2010) (equal-protection basis for credit rules)
State v. Dewey, 2013-Ohio-2118 (Ohio 2013) (recognizes no credit where defendant serves time for separate offense)
State v. Ayers, 2013-Ohio-4234 (Ohio 2013) (continues established rule on jail-time credit)
State v. Carter, 2013-Ohio-5163 (Ohio 2013) (reiterates no credit for unrelated offenses)