State v. Gates

Citations

• 2022 Ohio 3386

Syllabus

When a trial court sentences a defendant to time served for a community-control violation, the defendant is not entitled to have equivalent jail-time credit applied against a subsequently imposed felony sentence. The community-control-violation sentence has been completed and is not being served concurrent to the felony sentence. The time that a defendant spends in jail between an arrest on felony charges until a preliminary finding that the defendant violated community control in a previous case relates exclusively to the felony charges. Therefore the defendant should be granted jail-time credit against the felony sentence.