State v. Woodward, 2012 Ohio 632

Woodward was indicted in 2010CR2237 on aggravated burglary, robbery, kidnapping, and tampering with evidence related to July 15, 2010.
He pleaded guilty to aggravated burglary and robbery on September 24, 2010; kidnapping and tampering charges were dismissed.
A second case, 2010CR3275, charged him with two counts of receiving stolen property from July 4, 2010, to which he pled guilty on December 30, 2010.
The trial court ordered concurrent sentences in 2010CR2237 (eight years) and 2010CR3275 (six months), to be served consecutively for a total of eight and one-half years, with 114 days jail time credit.
On appeal, Woodward challenged the jail-time credit, arguing entitlement to 182 days of credit for pretrial confinement.
The appellate court affirmed, holding that jail-time credit is applied to the total concurrent term and that the record failed to establish the arrest date necessary to award additional credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether jail-time credit must be increased beyond 114 days	Woodward: entitled to 182 days credit for pretrial confinement	State: record insufficient to confirm arrest date; credit limited to entered amount	Credit applied to total concurrent term; record insufficient to grant more

State v. Fugate, 117 Ohio St.3d 261 (Ohio Supreme Court 2008) (concurrent terms require jail-time credit against total term; equal protection)
Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (Ohio Supreme Court 1980) (burden on appellant to show error by record reference; presumptively valid trial court)