jail-time credit error (Ohio) · Go Syfert
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jail-time credit error in Ohio

8 Ohio opinions name it 1 courts 2003–2022 2 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
State v. Cantygreen
ohioctapp · 2015 · cited in 1 Ohio opinions naming this issue, 2019–2019
1 sentence

2019Franklin No. 15AP-715, 2015-Ohio-5241, ¶9 (“Prior to the enactment of R.C. 2929.19(B)(2)(g)(iii), this court held that motions for jail-time credit were subject to the doctrine of res judicata except when the alleged calculation error was clerical or mathematical. * * * The enactment of this statute expanded the ability of a defendant to challenge an alleged jail-time credit error.”). {¶20} We find these recent decisions persuasive.

11
State v. Papczungreen
ohioctapp · 2013 · cited in 1 Ohio opinions naming this issue, 2013–2013
1 sentence

2013Summit No. 26560, 2013-Ohio-1162, ¶ 12 (Belfance, J., concurring in judgment only) (suggesting that a trial court may have limited jurisdiction to correct a jail-time credit error upon consideration of a motion filed under Section 2929.19(B)(2)(g)(iii)).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Grava v. Parkman Township green
ohio · 1995
2 sentences

2022O'Malley v. Russo, 156 Ohio St. 3d 548 , 2019-Ohio-1698 , 130 N.E.3d 256 , ¶ 27 quoting Grava v. Parkman Twp., 73 Ohio St.3d 379 , 653 N.E.2d 226 (1995), syllabus. {¶16} Appellant did raise the alleged jail-time-credit error in his previously- filed motion for judicial release.

2022O'Malley v. Russo, 156 Ohio St. 3d 548 , 2019-Ohio-1698 , 130 N.E.3d 256 , ¶ 27 quoting Grava v. Parkman Twp., 73 Ohio St.3d 379 , 653 N.E.2d 226 (1995), syllabus. {¶16} Appellant did raise the alleged jail-time-credit error in his previously- filed motion for judicial release.

12022–2022
State ex rel. O'Malley v. Russo (Slip Opinion) green
ohio · 2019
2 sentences

2022O'Malley v. Russo, 156 Ohio St. 3d 548 , 2019-Ohio-1698 , 130 N.E.3d 256 , ¶ 27 quoting Grava v. Parkman Twp., 73 Ohio St.3d 379 , 653 N.E.2d 226 (1995), syllabus. {¶16} Appellant did raise the alleged jail-time-credit error in his previously- filed motion for judicial release.

2022O'Malley v. Russo, 156 Ohio St. 3d 548 , 2019-Ohio-1698 , 130 N.E.3d 256 , ¶ 27 quoting Grava v. Parkman Twp., 73 Ohio St.3d 379 , 653 N.E.2d 226 (1995), syllabus. {¶16} Appellant did raise the alleged jail-time-credit error in his previously- filed motion for judicial release.

12022–2022
State v. Brown neutral
ohioctapp · 2018
1 sentence

2021Preble No. CA2017-09-010, 2018-Ohio-3338, ¶ 17 .

12021–2021
State v. Smith green
ohioctapp · 2014
1 sentence

2019Geauga No. 2014-G-3185, 2014-Ohio-5076, ¶ 15 , quoting R.C. 2953.08(G)(2). {¶12} We note that prior to the enactment of R.C. 2929.19(B)(2)(g)(iii) in 2012, an offender could only seek correction of a jail time credit error on direct appeal or the matter would be barred by res judicata.

12019–2019
State v. O'Brien green
ohio · 1987
1 sentence

2018In addition, the court observed that the jail time credit analysis was “somewhat convoluted in that the Defendant was sentenced on a revocation case arising out of the same facts as the herein case.” Id.

12018–2018
State ex rel. Williams v. McGinty green
ohio · 2011
2 sentences

2013Williams v. McGinty, 129 Ohio St.3d 275 , 2011-Ohio-2641 , 951 N.E.2d 755 .

2013Williams v. McGinty, 129 Ohio St.3d 275 , 2011-Ohio-2641 , 951 N.E.2d 755 .

12013–2013
State v. Ruby green
ohioctapp · 2002
1 sentence

2003And, like a motion to suppress, an objection grounded on a defendant's R.C. 2967.191 right and the court's duty to enforce it is determined on a preponderance of the evidence standard, not the reasonable doubt standard. {¶ 22} As a final matter, the State asks us to revisit our holding in State v. Ruby, 149 Ohio App.3d 541 , 2002-Ohio-5381 , to the extent that it conflicts with our holding in State v. Zuder (Feb. 7, 1997), Champaign App. No. 96-CA-11.

12003–2003

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2929.19 (7) OH § Ohio Rev. Code § 2967.191 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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