State v. Williams
2018 Ohio 3989
Ohio Ct. App.2018Background
- Chandler D. Williams pled guilty to felony possession of heroin (Jan 2014) and to attempted bribery (Apr 2015), and received five-year community-control terms in each case.
- Multiple notices of alleged community-control violations were filed (2016 and 2017); Williams admitted violations and the court continued community control twice before ultimately revoking it.
- On Jan 3, 2018 the trial court revoked community control and sentenced Williams to concurrent 180-day prison terms, awarding 21 days’ jail-time credit in one case and none in the other; sentencing entries also imposed court costs though costs were not mentioned at the hearing.
- Williams appealed and sought appellate bond and a stay; this court conditionally stayed the sentences pending appeal if Williams posted $5,000 bond, which he did not, and records show he subsequently was released after serving the terms.
- The appeal raises (1) a challenge to the calculation of jail-time credit and (2) a challenge to imposition of court costs without on-the-record notice at sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court erred in awarding only 21 days (and none in the other case) of jail-time credit | State: sentence and credit were properly imposed as entered | Williams: entitled to 318 days’ confinement credit against 180-day sentence for preplea and CCC confinement; failure violated statutes and equal protection | Moot — Williams already served his sentences and was released, so no relief available; assignment dismissed as moot |
| Whether imposing court costs in the judgment without addressing costs at sentencing requires remand | State: court entry valid and costs can be addressed postconviction | Williams: under State v. Joseph, imposing costs without on-the-record discussion deprived him of opportunity to request waiver; remand necessary | Overruled — Joseph displaced by R.C. 2947.23(C) and State v. Beasley; trial court retains jurisdiction to waive costs at sentencing or anytime after, so no remand required |
Key Cases Cited
- State ex rel. Compton v. Sutula, 132 Ohio St.3d 35 (2012) (holding jail-credit challenges become moot once sentence is fully served)
- State ex rel. Gordon v. Murphy, 112 Ohio St.3d 329 (2006) (same mootness principle)
- Crase v. Bradshaw, 108 Ohio St.3d 212 (2006) (appeal moot where sentence expired)
- State v. Joseph, 125 Ohio St.3d 76 (2010) (previously required on-the-record notice of costs; later displaced by statutory amendment and Beasley)