State v. Springs, 2022 Ohio 4414

Defendant Cory Springs pled guilty to one count of third-degree felony robbery and was sentenced to 36 months’ imprisonment, with postrelease control "for up to three years, but not less than one year," to run concurrent to a separate Clark County case.
At sentencing, the trial court did not calculate or mention jail-time credit for pretrial confinement and did not orally advise Springs of the consequences for violating postrelease control.
The written sentencing entry omitted any jail-time credit calculation but did include the postrelease-control consequences language.
The State conceded both sentencing errors on appeal; Springs argued the court erred by failing to (1) determine and award jail-time credit and (2) advise him at the sentencing hearing of postrelease-control consequences.
The appellate court agreed, sustaining both assignments of error and remanding for a limited resentencing: (a) to impose postrelease control properly, (b) to make a factual determination of jail-time credit, and (c) to issue an amended judgment entry reflecting the credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court failed to calculate/mention jail-time credit	State concedes error; trial court must determine and include credit in entry	Springs: court erred by not calculating or notifying him of jail-time credit	Sustained; remand for trial court to make factual determination of jail-time credit and issue amended entry
Trial court failed to advise at sentencing of consequences for violating postrelease control	State concedes error; advisement must occur at sentencing hearing	Springs: advisements at plea hearing and in entry do not cure failure at sentencing	Sustained; postrelease-control portion set aside and remanded for limited resentencing to impose postrelease control properly

State v. Fugate, 117 Ohio St.3d 261, 883 N.E.2d 440 (2008) (R.C. 2967.191 codifies entitlement to jail-time credit).
State ex rel. Rankin v. Ohio Adult Parole Auth., 98 Ohio St.3d 476, 786 N.E.2d 1286 (2003) (trial court must make factual determination of days of confinement to credit).
State v. Jordan, 104 Ohio St.3d 21, 817 N.E.2d 864 (2004) (trial court must notify offender of postrelease control at sentencing hearing).
State v. Grimes, 151 Ohio St.3d 19, 85 N.E.3d 700 (2017) (oral advisements must be incorporated into sentencing entry).
State v. Harper, 160 Ohio St.3d 480, 159 N.E.3d 248 (2020) (errors in imposing postrelease control render judgment voidable on direct appeal).
State v. Bates, 167 Ohio St.3d 197, 190 N.E.3d 610 (2022) (trial court must advise offender of term, discretionary/mandatory nature, and consequences of violating postrelease control).