Notes of Decisions
Cited in
499
cases (
167 in the last 5 years), 1969–2026 · leading case:
State v. Tuomala, 104 Ohio St. 3d 93 (Ohio 2004).
State v. Tuomala, 104 Ohio St. 3d 93 (Ohio 2004).
· cites it 34× “{¶ 5} On appeal, the Eleventh District Court of Appeals reversed the judgment of the trial court, holding that the court should have applied R.C. 2967.191 and credited Tuomala with time served prior to the court’s finding him not guilty by reason of insanity.”
State v. Gall, 2016 Ohio 2748 (Ohio Ct. App. 2016).
· cites it 64× “The State also argued that the OBSC’s calculation was incorrect because R.C. 2967.191 does not permit jail-time credit to be awarded for time served on unrelated offenses.”
State v. Reed (Slip Opinion), 2020 Ohio 4255 (Ohio 2020).
· cites it 21× “] Criminal law—R.C. 2967.191(A)—Jail-time credit—Postconviction house arrest and electronic monitoring—Jail-time credit is given for confinement in a public or private facility, not in a residence—A defendant is not entitled to jail-time credit for days he spent in…”
State v. Porter, 2018 Ohio 3852 (Ohio Ct. App. 2018).
· cites it 54× “01(P), the majority held that a defendant subject to house arrest qualifies for jail-time credit for purposes of being "confined" pursuant to R.C. 2967.191. {¶ 6} In a well-reasoned dissent, Judge Robert A.”
State, Ex Rel. Corder v. Wilson, 589 N.E.2d 113 (Ohio Ct. App. 1991).
· cites it 13× “Corder, requiring respondents to credit, pursuant to R.C. 2967.191, the proper number of days that he was confined because of the offense for which he was convicted and sentenced.”
State v. Williams, 2017 Ohio 5598 (Ohio Ct. App. 2017).
· cites it 7× “R.C. 2967.191 provides that a prisoner shall receive jail-time credit for "the total number of days that the prisoner was confined for any reason arising out of the offense for which the prisoner was convicted and sentenced, including confinement in lieu of bail while awaiting…”
State v. Moore (Slip Opinion), 2018 Ohio 3237 (Ohio 2018).
· cites it 6× “{¶ 10} In this case, Moore seeks to have the time he spent in the county jail credited toward his sentence pursuant to R.C. 2967.191 ("the jail-time-credit provision").”
State v. Fugate, 883 N.E.2d 440 (Ohio 2008).
· cites it 4× “191, which states that “[t]he department of rehabilitation and correction shall reduce the stated prison term of a prisoner * * * by the total number of days that the prisoner was confined for any reason arising out of the offense for which the prisoner was convicted and…”
State v. Delvallie, 2022 Ohio 470 (Ohio Ct. App. 2022).
· cites it 2× “Under the Reagan Tokes Law, a defendant is sentenced to a “minimum prison term” that the court may choose from the listed term choices in the statute: (1) “Offender’s minimum prison term” means the minimum prison term imposed on an offender under a non-life felony indefinite…”
State v. Cupp, 124 N.E.3d 811 (Ohio 2018).
· cites it 4× “{¶ 9} Cupp appealed to the Eleventh District Court of Appeals, arguing entitlement to an award of jail-time credit from the time the court revoked his bond on the felony charges.”
State v. Napier, 2001 Ohio 1890 (Ohio 2001).
· cites it 5× “The issue in this case is whether the entire amount of time served in a CBCF qualifies as “confinement” according to R.C. 2967.191 and should therefore be credited towards a prison sentence after conditions of the community sanctions are violated.”
State v. Christian (Slip Opinion), 2020 Ohio 828 (Ohio 2020).
· cites it 5× “Credit for Time Served {¶ 53} The state argues that the trial court’s order of consecutive sentences was not a double-jeopardy violation because, once applied, Ohio’s jail-time-credit statute, R.C. 2967.191, prevents the time that Christian already served as punishment for Count…”
— Ohio Rev. Code § 2967.191(A) — 101 cases
State v. Reed (Slip Opinion), 2020 Ohio 4255 (Ohio 2020).
“] Criminal law—R.C. 2967.191(A)—Jail-time credit—Postconviction house arrest and electronic monitoring—Jail-time credit is given for confinement in a public or private facility, not in a residence—A defendant is not entitled to jail-time credit for days he spent in…”
State v. Christian (Slip Opinion), 2020 Ohio 828 (Ohio 2020).
“Credit for Time Served {¶ 53} The state argues that the trial court’s order of consecutive sentences was not a double-jeopardy violation because, once applied, Ohio’s jail-time-credit statute, R.C. 2967.191, prevents the time that Christian already served as punishment for Count…”
— Ohio Rev. Code § 2967.191(A)(1) — 2 cases
— Ohio Rev. Code § 2967.191(B) — 2 cases
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