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State ex Rel. Jones v. O'Connor

Supreme Court of Ohio
Feb 10, 1999
84 Ohio St. 3d 426 (Ohio 1999)

Summary

concluding the duty to grant pretrial confinement credit rests with OAPA, not the sentencing judge

Summary of this case from Pollock v. Ohio Adult Parole Auth.

Opinion

No 98-1782

Submitted December 16, 1998

Decided February 10, 1999.

APPEAL from the Court of Appeals for Hamilton County, No. C-980431.

In May 1998, appellant, Dennis R. Jones, filed a complaint in the Court of Appeals for Hamilton County. Jones requested a writ of mandamus to compel appellee, Hamilton County Common Pleas Court Judge John O'Connor, to grant his motion for jail-time credit because Judge O'Connor had not ruled on the motion. Judge O'Connor filed motions to dismiss Jones's complaint. In one of the motions, Judge O'Connor asserted that the mandamus claim was moot because he had denied Jones's motion for jail-time credit in a June 1998 entry. In the June 1998 entry, Judge O'Connor found that Jones had already received twenty-three days of jail-time credit and that he was not entitled to any more credit.

The court of appeals granted Judge O'Connor's motions and dismissed Jones's mandamus complaint.

This cause is now before the court upon an appeal as of right.

Dennis R. Jones, pro se.


Jones asserts that the court of appeals erred in dismissing his complaint for a writ of mandamus. For the following reasons, however, we find this assertion to be meritless.

First, to the extent that Jones requested that Judge O'Connor rule on his motion for jail-time credit, his claim was rendered moot when Judge O'Connor subsequently denied the motion. Mandamus does not lie to compel an act that has already been performed. State ex rel Wynn v. McCormick (1998), 82 Ohio St.3d 420, 421, 696 N.E.2d 593.

Second, Jones had an adequate remedy at law by appeal to review any sentencing error by Judge O'Connor in failing to calculate his correct jail-time credit. See, e.g., State ex rel Sampson v. Parrott (1998), 82 Ohio St.3d 92, 93, 694 N.E.2d 463.

Finally, the duty under R.C. 2967.191 to actually grant pretrial-confinement time credit rests with the Adult Parole Authority rather than Judge O'Connor. State ex rel. Harrell v. Hamilton Cty. Court of Common Pleas (1979), 58 Ohio St.2d 193, 12 O.O.3d 189, 389 N.E.2d 506; State ex rel. Gooden v. Martin (1990), 67 Ohio App.3d 685, 588 N.E.2d 185.

Based on the foregoing, we affirm the judgment of the court of appeals.

Judgment affirmed.

MOYER, C.J., DOUGLAS, RESNICK, F.E. SWEENEY, PFEIFER, COOK and LUNDBERG STRATTON, JJ., concur.


Summaries of

State ex Rel. Jones v. O'Connor

Supreme Court of Ohio
Feb 10, 1999
84 Ohio St. 3d 426 (Ohio 1999)

concluding the duty to grant pretrial confinement credit rests with OAPA, not the sentencing judge

Summary of this case from Pollock v. Ohio Adult Parole Auth.

denying petition for writ of mandamus compelling trial court to rule on defendant's motion for additional jail time credit

Summary of this case from State v. Harbert

In Jones, the Supreme Court of Ohio held that the relator was not entitled to a writ of mandamus because he could have appealed any error by the trial court in calculating his jail-time credit.

Summary of this case from State v. Williamson

stating that an appeal is an adequate remedy by which to review sentencing errors in failing to calculate correct jail time credit

Summary of this case from State v. Walker

In Jones, supra, the Supreme Court emphasized that, if a defendant believes that the trial judge has made an error in calculating his jail-time credit, the proper remedy for him to pursue is a direct appeal from that determination.

Summary of this case from State ex Rel. Jaryga v. Mitrovich

stating that an appeal is an adequate remedy by which to review sentencing errors in failing to calculate correct jail time credit

Summary of this case from State v. Denman

stating that an appeal is an adequate remedy by which to review sentencing errors in failing to calculate correct jail time credit

Summary of this case from State v. Redman
Case details for

State ex Rel. Jones v. O'Connor

Case Details

Full title:THE STATE EX REL.] JONES, APPELLANT, v. O'CONNOR, JUDGE, APPELLEE

Court:Supreme Court of Ohio

Date published: Feb 10, 1999

Citations

84 Ohio St. 3d 426 (Ohio 1999)
704 N.E.2d 1223

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