Shinzo Abe’s Biggest Failure Is His Greatest Legacy: Preservation of Japan’s Anti-Military Constitutional Provision

MICHAEL C. DORF

In response to the news that Japan’s Prime Minister Shinzo Abe resigned due to health reasons, Cornell law professor Michael C. Dorf comments on Abe’s efforts to amend Article 9 of Japan’s Constitution, which was imposed on the country by Supreme Allied Commander Douglas MacArthur after World War II. Dorf describes one bad reason and two good reasons that have been offered for a change in Article 9, but he argues that the case for retaining Article 9 is stronger.

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State v. Reed

Citation: 2020-Ohio-4255

Opinion Date: September 1, 2020

Judge: Sharon L. Kennedy

Areas of Law: Criminal Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment denying jail-time credit for the days Defendant was on postconviction house arrest and postconviction electronic monitoring, holding that Defendant was not entitled to jail-time credit for these days. Defendant pled guilty to a charge involving criminal gang activity and was sentenced to community-control sanctions. Defendant was later placed on house arrest after he violated terms of his community control and was then placed on electronic monitoring after new charges were brought against him. During a hearing, Defendant filed a motion asserting that he was entitled to jail-time credit for the time he was on standard house arrest and electronic monitoring. The trial court denied the motion and imposed a sentence. The appellate court reversed, concluding that Defendant was entitled to jail-time credit for the time he was on house arrest and electronic monitoring. The Supreme Court reversed, holding that Ohio Rev. Code 2969.191(A) is plain and unambiguous, limits a jail-time credit to specific types of confinement, and does not provide for a reduction in sentence for a term of postconviction house arrest or electronic monitoring imposed for violating community-control sanctions.