2020 Ohio 1145
Ohio Ct. App.2020Background
- Greene County indicted Steinmetz May 18, 2018; he was served July 24, 2018 while confined in the Montgomery County jail on separate charges (detained there since June 22, 2018).
- Sept 13, 2018: Montgomery County sentenced him to community control with an in‑custody MonDay treatment program (which he began immediately).
- Jan 31, 2019: Steinmetz pled guilty in Greene County; sentencing was set for Mar 28, 2019 but he failed to appear; a capias issued and he was arrested April 22, 2019 and held in Greene County until sentencing.
- June 5, 2019: Greene County imposed a two‑year prison term and awarded 43 days of jail‑time credit; the trial court later denied Steinmetz’s motion for additional credit (claiming July 24–Mar 28, 2019).
- The appellate court analyzed R.C. 2967.191 and authorities on simultaneous pretrial confinement and whether credit accrues when multiple cases overlap and sentences are concurrent or consecutive.
- Holding: the court awarded an additional 52 days (July 24–Sept 13, 2018) plus corrected the April 22–June 5, 2019 credit to 45 days, for a total of 97 days; it reversed and remanded to enter that credit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Steinmetz is entitled to jail‑time credit in the Greene County sentence for time detained in Montgomery County from July 24–Sept 13, 2018 (52 days) | Greene: confinement resulted from Montgomery offense, not the Greene offense, so no Greene credit | Steinmetz: he was in simultaneous pretrial confinement on both cases and received no credit elsewhere for those 52 days, so Greene credit is required | Appellate court: awarded the 52 days to Greene County sentence because he received no credit in Montgomery and simultaneous pretrial confinement supports credit here; total credit corrected to 97 days |
Key Cases Cited
- State v. Cupp, 124 N.E.3d 811 (Ohio 2018) (defendant not entitled to jail‑time credit while serving a sentence on an unrelated case)
- State v. Fugate, 883 N.E.2d 440 (Ohio 2008) (where sentences are consecutive, jail‑time credit applies so that overall prison term is reduced and credit need only be applied to one term)