State v. Little

Summary

The Eleventh District Court of Appeals of Ohio affirmed the Portage County Court of Common Pleas' denial of Angel Little's motions for additional jail-time credit. The court held that Little was properly awarded 408 days of credit and that, because his prison sentences were consecutive, the credit applied only once to the aggregate sentence. The court also held that post-sentencing conveyance credit was properly left for calculation by the Ohio Department of Rehabilitation and Correction.

Holdings

1. The trial court did not abuse its discretion because Little was entitled to 408 days of jail-time credit, which the trial court had already awarded.
2. When prison sentences are consecutive, accrued jail-time credit is applied only once to the aggregate prison term and is not duplicated across the consecutive sentences.
3. The sentencing court's jail-time-credit calculation extends through the sentencing date; the Ohio Department of Rehabilitation and Correction is responsible for independently calculating credit for post-sentencing confinement while the prisoner awaits transportation to the place of imprisonment.

Questions Presented

1. Whether the trial court abused its discretion by denying Little's motions for additional or corrected jail-time credit.
2. Whether jail-time credit accrued while a defendant is serving or awaiting consecutive sentences must be applied more than once to separate prison terms.
3. Whether time spent incarcerated after sentencing while awaiting conveyance to a reception facility must be calculated by the sentencing court or by the Ohio Department of Rehabilitation and Correction.

Disposition

affirmed