State v. Williams

2025 Ohio 1411 · Court of Appeals of Ohio, Third Appellate District · April 21, 2025 · No. 8-24-44

Summary

This appellate court opinion reviews a criminal defendant's appeal from the denial of his motion for additional jail-time credit. The defendant argued that the trial court miscalculated his pre-sentence detention credit, but the appellate court found he failed to provide sufficient evidence linking his confinement specifically to the offenses at issue. Consequently, the court affirmed the trial court's judgment.

Court
Court of Appeals of Ohio, Third Appellate District
Writing for the Court
Waldick, P.J.; Miller; Willamowski
Jurisdiction
Ohio
Decision date
April 21, 2025
Docket number
8-24-44
Procedural posture
Appeal from Logan County Common Pleas Court, General Division, judgment affirmed.
Standard of review
abuse of discretion
Precedential value
published
Parties
David J. Williams v. State of Ohio
Disposition
affirmed

Topics

sentencingsentencing guidelinesappellate jurisdictionstandard of review

Practice areas

criminal procedureappellate procedure

Questions Presented

  1. Whether the trial court erred in denying Williams's motion for additional jail‑time credit
  2. Whether the trial court abused its discretion in calculating jail‑time credit

Holdings

  1. The trial court did not err; Williams failed to provide proof of additional credit and the denial was proper.

Key quotations

Trial courts have a duty to calculate jail-time credit at the time of sentencing; however, the trial court retains jurisdiction to correct errors not previously raised at sentencing. (¶10)
Having found no error prejudicial to Williams in the particulars assigned and argued, his assignment of error is overruled and the judgment of the Logan County Common Pleas Court is affirmed. (¶13)

Factual background

Williams was indicted on seven offenses in October 2022, pleaded guilty to intimidation and an assault charge, and received an aggregate two‑year prison term with 128 days of jail‑time credit. He later claimed he was entitled to additional credit, but the trial court found no supporting evidence and denied his motion.

Procedural history

Williams was indicted on multiple charges, entered a negotiated plea, received jail‑time credit at sentencing, and later moved for additional credit. The trial court denied the motion; Williams appealed alleging a Fourteenth Amendment violation.

Remand instructions

The cause is remanded to the trial court for execution of the judgment and assessment of costs.

Court Document

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