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State v. Lutz
Citation: 2017 Ohio 4077Docket: 105595
Court: Ohio Court of Appeals; June 1, 2017; Ohio; State Appellate Court
Original Court Document: View Document
Ronald Lutz appealed the trial court's decision granting him 177 days of jail-time credit, arguing he should receive 212 days for his confinement from February 1 to August 31, 2001, related to three criminal cases. Lutz presented evidence of his detention in Lakewood city jail and Cuyahoga County jail, including time spent at Northcoast Behavioral Center for a court-ordered psychiatric evaluation. The trial court denied credit for the time in Lakewood city jail and at Northcoast, leading to Lutz's appeal. The state of Ohio conceded the error, suggesting Lutz should receive 211 days instead. The Court of Appeals agreed with Lutz, sustained his assignment of error, and reversed the trial court's judgment, remanding the case with instructions to award the correct jail-time credit. R.C. 2967.191 mandates that the Department of Rehabilitation and Correction must reduce a prisoner's term by the total days of confinement related to the offense, including bail confinement, competency evaluations, and transportation delays. R.C. 2929.19(B)(2)(g)(iii) allows a sentencing court to correct errors in the calculation of jail-time credit at any time post-sentencing, with the requirement that any changes be promptly communicated to the Department. Ohio case law supports that confinement time must be credited towards a prison term, with definitions of 'confinement' including any institutional setting where freedom is restricted. R.C. 2948.38(I) further stipulates that time spent for competency evaluations or treatment must be credited towards a sentence. In the case at hand, Lutz was confined for 212 days in various facilities from February 1 to August 31, 2001, but the trial court erroneously credited him with only 177 days. The state acknowledged the error but suggested a credit of 211 days. The court determined that Lutz is entitled to the full 212 days of credit. The trial court's decision was reversed, and it was instructed to properly credit Lutz upon remand. The appeal was found to have reasonable grounds, and costs were to be recovered by Lutz.