State v. Moore
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At issue was whether an exception in Ohio law providing that jail-time credit does not apply to the portion of a prison sentence that is imposed for a firearm specification, as applied in this case, violates equal-protection guarantees.
Defendant was sentenced to an aggregate prison term that included two mandatory terms for firearm specifications. Before sentencing, Defendant filed a motion to credit the time that he had served in jail prior to sentencing toward the four years that he needed to serve for the firearm specifications. The trial court determined that the jail-time credit should be applied only to Defendant’s prison terms imposed for the underlying felonies. The court of appeals reversed, concluding that the failure to apply jail-time credit to Defendant’s firearm-specification terms would risk an equal protection violation should Defendant be granted judicial release. The Supreme Court revered, holding (1) the plain language of Ohio Rev. Code 2929.14(B)(1)(b) does not allow jail-time credit to be applied to mandatory firearm-specification sentences; and (2) there was no equal protection violation in this case.
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