State v. Hurst

Citations

• 2018 Ohio 142
• 93 N.E.3d 1007

Syllabus

The trial court erred by granting appellee 17 days of jail-time credit for the time she spent on electronically monitored house arrest following her conviction for one count of unauthorized use of property for, when applying the so-called \restraint of movement\ reasoning rather than a strict textual interpretation of the relevant statutes, appellee's freedom of movement was not in any way restrained such that she could not leave her home on her own volition, despite the fact that it would constitute a violation of her community control sanctions and potentially subject her to prosecution for escape, so as to be entitled to receive jail-time credit for her time spent on electronically monitored house arrest.