Barker factors (Ohio) · Go Syfert
← Ohio issues

Barker factors in Ohio

129 Ohio opinions name it 4 courts 1985–2026 31 in the last five years

The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (38)

CaseFollowedCited
Doggett v. United Statesgreen
scotus · 1992 · cited in 50 Ohio opinions naming this issue, 1997–2025
2 sentences

2024“A delay becomes presumptively prejudicial as it approaches one year in length.” State v. Adams, 2015-Ohio-3954, ¶ 90 , citing Doggett v. United States, 505 U.S. 647, 652, fn. 1 (1992). {¶ 41} Assuming (without deciding) that the approximately four-month delay triggered a Barker analysis, the delay was not sufficiently prejudicial to merit the dismissal of the charges against Rasheed.

2024“A delay becomes presumptively prejudicial as it approaches one year in length.” State v. Adams, 2015-Ohio-3954, ¶ 90 , citing Doggett v. United States, 505 U.S. 647, 652, fn. 1 (1992). {¶ 41} Assuming (without deciding) that the approximately four-month delay triggered a Barker analysis, the delay was not sufficiently prejudicial to merit the dismissal of the charges against Rasheed.

1250
Barker v. Wingogreen
scotus · 1972 · cited in 35 Ohio opinions naming this issue, 1990–2026
2 sentences

2025However, Appellant claims that the Ohio Supreme Court has created an exception when a defendant seeks to challenge a constitutional violation of speedy trial rights based in part on Barker v. Wingo, 407 U.S. 514 (1972). {¶9} Before engaging in a Barker analysis, we must determine whether Appellant waived her right to challenge an alleged speedy trial violation due to her guilty plea.

2025However, Appellant claims that the Ohio Supreme Court has created an exception when a defendant seeks to challenge a constitutional violation of speedy trial rights based in part on Barker v. Wingo, 407 U.S. 514 (1972). {¶9} Before engaging in a Barker analysis, we must determine whether Appellant waived her right to challenge an alleged speedy trial violation due to her guilty plea.

835
State v. Searsgreen
ohioctapp · 2005 · cited in 7 Ohio opinions naming this issue, 2008–2023
2 sentences

2023This has led to inconsistent results. {¶15} In State v. Sears, 166 Ohio App.3d 166 , 2005-Ohio-5963 , 849 N.E.2d 1060 (1st Dist.), we found that a nine-month delay triggered the Barker analysis.

2023This has led to inconsistent results. {¶15} In State v. Sears, 166 Ohio App.3d 166 , 2005-Ohio-5963 , 849 N.E.2d 1060 (1st Dist.), we found that a nine-month delay triggered the Barker analysis.

47
State v. Rentasgreen
ohioctapp · 2022 · cited in 4 Ohio opinions naming this issue, 2024–2026
2 sentences

2026“Deliberate dilatory acts are weighted heavily against the state, while negligent acts are weighted less heavily against the state.” State v. Duncan, 2021-Ohio-3229, ¶ 16 (1st Dist.), citing Barker at 531 . “[I]ntertwined within this Barker analysis is whether the defendant shares any responsibility for the delay.” State v. Rentas, 2022-Ohio-2412, ¶ 32 (8th Dist.), citing Triplett at 570 . 6 {¶ 14} Regarding a defendant’s assertion of his right to a speedy trial, “‘[i]t is well established under our law that the right to a speedy trial conferred by the Constitution is not self-executing.’” Sta

2026“Deliberate dilatory acts are weighted heavily against the state, while negligent acts are weighted less heavily against the state.” State v. Duncan, 2021-Ohio-3229, ¶ 16 (1st Dist.), citing Barker at 531 . “[I]ntertwined within this Barker analysis is whether the defendant shares any responsibility for the delay.” State v. Rentas, 2022-Ohio-2412, ¶ 32 (8th Dist.), citing Triplett at 570 . 6 {¶ 14} Regarding a defendant’s assertion of his right to a speedy trial, “‘[i]t is well established under our law that the right to a speedy trial conferred by the Constitution is not self-executing.’” Sta

44
State v. Duncangreen
ohioctapp · 2021 · cited in 4 Ohio opinions naming this issue, 2025–2026
2 sentences

2026“Deliberate dilatory acts are weighted heavily against the state, while negligent acts are weighted less heavily against the state.” State v. Duncan, 2021-Ohio-3229, ¶ 16 (1st Dist.), citing Barker at 531 . “[I]ntertwined within this Barker analysis is whether the defendant shares any responsibility for the delay.” State v. Rentas, 2022-Ohio-2412, ¶ 32 (8th Dist.), citing Triplett at 570 . 6 {¶ 14} Regarding a defendant’s assertion of his right to a speedy trial, “‘[i]t is well established under our law that the right to a speedy trial conferred by the Constitution is not self-executing.’” Sta

2026“Deliberate dilatory acts are weighted heavily against the state, while negligent acts are weighted less heavily against the state.” State v. Duncan, 2021-Ohio-3229, ¶ 16 (1st Dist.), citing Barker at 531 . “[I]ntertwined within this Barker analysis is whether the defendant shares any responsibility for the delay.” State v. Rentas, 2022-Ohio-2412, ¶ 32 (8th Dist.), citing Triplett at 570 . 6 {¶ 14} Regarding a defendant’s assertion of his right to a speedy trial, “‘[i]t is well established under our law that the right to a speedy trial conferred by the Constitution is not self-executing.’” Sta

44
Byrnes v. LCI Communication Holdings Co.green
ohio · 1996 · cited in 5 Ohio opinions naming this issue, 1999–2004
2 sentences

2004Nonetheless, because only Barker’s second prong was at issue in Mauzy , we did not further discuss O’Connor or Barker’s fourth prong. {¶ b} In Byrnes, 77 Ohio St.3d 125 , 672 N.E.2d 145 , we again iterated the Barker test.

2004Nonetheless, because only Barker’s second prong was at issue in Mauzy , we did not further discuss O’Connor or Barker’s fourth prong. {¶ b} In Byrnes, 77 Ohio St.3d 125 , 672 N.E.2d 145 , we again iterated the Barker test.

25
State v. Long (Slip Opinion)green
ohio · 2020 · cited in 3 Ohio opinions naming this issue, 2022–2025
2 sentences

2025See State v. Long, 2020-Ohio-5363, ¶ 29 (Kennedy, J., concurring in judgment) (stating that she “would remand the cause to the court of appeals to evaluate [the] speedy-trial claim in light of this court’s decision clarifying the law”); see also Long at ¶ 31 (Fischer, 27 OHIO FIRST DISTRICT COURT OF APPEALS J., concurring in part and dissenting in part) (explaining that “because the court of appeals did not have the opportunity to consider this case in light of this court’s clarification of the law, I would remand the cause to the Second District so that it may weigh the Barker factors in the

2025See State v. Long, 2020-Ohio-5363, ¶ 29 (Kennedy, J., concurring in judgment) (stating that she “would remand the cause to the court of appeals to evaluate [the] speedy-trial claim in light of this court’s decision clarifying the law”); see also Long at ¶ 31 (Fischer, 27 OHIO FIRST DISTRICT COURT OF APPEALS J., concurring in part and dissenting in part) (explaining that “because the court of appeals did not have the opportunity to consider this case in light of this court’s clarification of the law, I would remand the cause to the Second District so that it may weigh the Barker factors in the

23
State v. Olliviergreen
wash · 2013 · cited in 2 Ohio opinions naming this issue, 2014–2019
2 sentences

2019See Hubbard, 2015-Ohio-646 , at ¶ 25-26; Stevens at ¶ 23-24, citing State v. Ollivier, 178 Wash.2d 813, 841 (2013); Owens, 2010-Ohio- 3353, at ¶ 16-17; Boyd, 2005-Ohio-1228, at ¶ 15 . {¶41} The delay caused by the State’s negligence in this case, while sufficient to raise a presumption of prejudice for purposes of triggering analysis of the Barker factors, was significantly shorter than the eight-and-one-half year delay at issue in Doggett.

2019See Hubbard, 2015-Ohio-646 , at ¶ 25-26; Stevens at ¶ 23-24, citing State v. Ollivier, 178 Wash.2d 813, 841 (2013); Owens, 2010-Ohio- 3353, at ¶ 16-17; Boyd, 2005-Ohio-1228, at ¶ 15 . {¶41} The delay caused by the State’s negligence in this case, while sufficient to raise a presumption of prejudice for purposes of triggering analysis of the Barker factors, was significantly shorter than the eight-and-one-half year delay at issue in Doggett.

22
State v. Triplettgreen
ohio · 1997 · cited in 14 Ohio opinions naming this issue, 2001–2024
2 sentences

2018Id. at 530 , 92 S.Ct. 2182 . {¶ 25} First, as to the "length of the delay," the Supreme Court of Ohio, in State v. Triplett , 78 Ohio St.3d 566 , 679 N.E.2d 290 (1997), held that the length of the delay acts as a triggering mechanism to determine the necessity of examining the remaining Barker factors.

2018Id. at 530 , 92 S.Ct. 2182 . {¶ 25} First, as to the "length of the delay," the Supreme Court of Ohio, in State v. Triplett , 78 Ohio St.3d 566 , 679 N.E.2d 290 (1997), held that the length of the delay acts as a triggering mechanism to determine the necessity of examining the remaining Barker factors.

114
State v. Davisgreen
ohio · 1976 · cited in 5 Ohio opinions naming this issue, 2008–2019
2 sentences

2019Barker v. Wingo, 407 U.S. 514, 530-532 , 92 S.Ct. 2182 (1972); State v. Davis, 46 Ohio St.2d 444, 446 (1976). {¶ 26} The first of the Barker factors, the length of delay, "is to some extent a triggering mechanism." Barker at 530 .

2019Barker v. Wingo, 407 U.S. 514, 530-532 , 92 S.Ct. 2182 (1972); State v. Davis, 46 Ohio St.2d 444, 446 (1976). {¶ 26} The first of the Barker factors, the length of delay, "is to some extent a triggering mechanism." Barker at 530 .

15
State v. Adams (Slip Opinion)green
ohio · 2015 · cited in 4 Ohio opinions naming this issue, 2021–2025
2 sentences

2025To the contrary, a prejudicial delay “serves as a triggering mechanism for the rest of the Barker analysis.” State v. Adams, 2015-Ohio-3954 , ¶ 89.

2024“A delay becomes presumptively prejudicial as it approaches one year in length.” State v. Adams, 2015-Ohio-3954, ¶ 90 , citing Doggett v. United States, 505 U.S. 647, 652, fn. 1 (1992). {¶ 41} Assuming (without deciding) that the approximately four-month delay triggered a Barker analysis, the delay was not sufficiently prejudicial to merit the dismissal of the charges against Rasheed.

14
State v. Triplettgreen
ohio · 1997 · cited in 2 Ohio opinions naming this issue, 2016–2025
2 sentences

2025See also State v. Triplett, 1997-Ohio-182, ¶ 17 (a delay of one year is generally enough to trigger an analysis of the remaining Barker factors).

2025See also State v. Triplett, 1997-Ohio-182, ¶ 17 (a delay of one year is generally enough to trigger an analysis of the remaining Barker factors).

12
State v. Yuen, Unpublished Decision (3-18-2004)green
ohioctapp · 2004 · cited in 2 Ohio opinions naming this issue, 2005–2019
2 sentences

2019Franklin No. 03A P-513, 2004-Ohio-1276, ¶ 10 .

2019Franklin No. 03A P-513, 2004-Ohio-1276, ¶ 10 .

12
State v. Irishgreen
ohioctapp · 2019 · cited in 1 Ohio opinions naming this issue, 2026–2026
2 sentences

2026See Irish at ¶ 42 (finding no prejudice because the defendant “was not threatened with the prospect to oppressive pretrial incarceration [because] his liberty was already severely restrained” in an unrelated case). {¶17} The balancing of the factors in the Barker analysis indicates that, even if Bernard had not waived his constitutional speedy-trial claim, he still has not demonstrated that his constitutional right to a speedy trial was violated. {¶18} Thus, Bernard’s assignment of error is overruled. -8- Case No. 3-25-06 {¶19} Having found no error prejudicial to the appellant herein in the p

2026See Irish at ¶ 42 (finding no prejudice because the defendant “was not threatened with the prospect to oppressive pretrial incarceration [because] his liberty was already severely restrained” in an unrelated case). {¶17} The balancing of the factors in the Barker analysis indicates that, even if Bernard had not waived his constitutional speedy-trial claim, he still has not demonstrated that his constitutional right to a speedy trial was violated. {¶18} Thus, Bernard’s assignment of error is overruled. -8- Case No. 3-25-06 {¶19} Having found no error prejudicial to the appellant herein in the p

11
Klopfer v. North Carolinagreen
scotus · 1967 · cited in 1 Ohio opinions naming this issue, 2025–2025
11
State v. Muhammadelgreen
ohioctapp · 2021 · cited in 1 Ohio opinions naming this issue, 2025–2025
2 sentences

2025“The Barker factors are related and must be considered together, along with such other circumstances as may 6 OHIO FIRST DISTRICT COURT OF APPEALS be relevant to protecting the purposes of the constitutional speedy-trial guarantee.” State v. Muhammadel, 2021-Ohio-567, ¶ 11 (1st Dist.). 1.

2025“The Barker factors are related and must be considered together, along with such other circumstances as may 6 OHIO FIRST DISTRICT COURT OF APPEALS be relevant to protecting the purposes of the constitutional speedy-trial guarantee.” State v. Muhammadel, 2021-Ohio-567, ¶ 11 (1st Dist.). 1.

11
State v. Johnsongreen
ohioctapp · 2024 · cited in 1 Ohio opinions naming this issue, 2025–2025
11
State v. Stormsgreen
ohioctapp · 2024 · cited in 1 Ohio opinions naming this issue, 2025–2025
11
State v. Brucegreen
ohioctapp · 2018 · cited in 1 Ohio opinions naming this issue, 2024–2024
11
Zoltan Takacs v. Ted Englegreen
ca6 · 1985 · cited in 1 Ohio opinions naming this issue, 2023–2023
11
United States v. Alexander T. Valentinegreen
ca9 · 1986 · cited in 1 Ohio opinions naming this issue, 2023–2023
11
United States v. James Henry Simmonsgreen
ca9 · 1976 · cited in 1 Ohio opinions naming this issue, 2023–2023
11
United States v. Clarke Dana Johnsongreen
ca1 · 1978 · cited in 1 Ohio opinions naming this issue, 2022–2022
11
United States v. Charles J. Jacksongreen
ca6 · 2007 · cited in 1 Ohio opinions naming this issue, 2022–2022
11
State v. Gagegreen
ohctapp1hamilto · 2018 · cited in 1 Ohio opinions naming this issue, 2022–2022
11
State v. Carpentergreen
ohioctapp · 2019 · cited in 1 Ohio opinions naming this issue, 2021–2021
11
David A. Maples v. Jimmy Stegall, Wardengreen
ca6 · 2005 · cited in 1 Ohio opinions naming this issue, 2020–2020
11
State v. Tategreen
ohio · 1979 · cited in 1 Ohio opinions naming this issue, 2019–2019
11
Vermont v. Brillongreen
scotus · 2009 · cited in 1 Ohio opinions naming this issue, 2018–2018
11
City of Billings v. Brucegreen
mont · 1998 · cited in 1 Ohio opinions naming this issue, 2018–2018
11
State v. Ariegwegreen
mont · 2007 · cited in 1 Ohio opinions naming this issue, 2018–2018
11
Edward ACKERMAN, Plaintiff-Appellant, v. DIAMOND SHAMROCK CORPORATION, Defendant-Appelleegreen
ca6 · 1982 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
State v. Ricegreen
ohioctapp · 2015 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
Stores Realty Co. v. City of Clevelandgreen
ohio · 1975 · cited in 1 Ohio opinions naming this issue, 2014–2014
11
United States v. Younggreen
ca6 · 2011 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
State v. Newberrygreen
ohioctapp · 1991 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
State v. Winngreen
ohioctapp · 2012 · cited in 1 Ohio opinions naming this issue, 2013–2013
11
State v. Myersgreen
ohio · 2002 · cited in 1 Ohio opinions naming this issue, 2011–2011
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Cruz v. South Dayton Urological Associates, Inc.green
ohioctapp · 1997 · cited in 2 Ohio opinions naming this issue, 1999–2000
2 sentences

2000Barnes v. GenCorp, Inc. (C.A.6, 1992), 896 F.2d 1457 , 1465 ; but see, Cruz v. South Dayton Urological Assoc. (1997), 121 Ohio App.3d 655 , 661 ("In the context in which the Barker test is applied, "replacement' is the substitution of an employee not belonging to the protected class for an employee who is a member of it.

2000Barnes v. GenCorp, Inc. (C.A.6, 1992), 896 F.2d 1457 , 1465 ; but see, Cruz v. South Dayton Urological Assoc. (1997), 121 Ohio App.3d 655 , 661 ("In the context in which the Barker test is applied, "replacement' is the substitution of an employee not belonging to the protected class for an employee who is a member of it.

12

Also cited on this issue (41)

CaseCitedYears
McDonnell Douglas Corp. v. Green green
scotus · 1973
2 sentences

2013The Barker analysis requires that the plaintiff-employee demonstrate “(1) that he was a member of the statutorily-protected class, (2) that he was discharged, (3) that he was qualified for the position, and (4) that he was replaced by or that his discharge permitted the retention of a person not belonging to the protected class.” Id., paragraph one of the syllabus.

2013The Barker analysis requires that the plaintiff-employee demonstrate “(1) that he was a member of the statutorily-protected class, (2) that he was discharged, (3) that he was qualified for the position, and (4) that he was replaced by or that his discharge permitted the retention of a person not belonging to the protected class.” Id., paragraph one of the syllabus.

131991–2013
State v. Selvage green
ohio · 1997
2 sentences

2013Brime at ¶ 11.; Mohamed at ¶ 21 citing State v. Selvage, 80 Ohio St. 3d 465 (1997) (adopting Barker test for purposes of Article I, Section 10 of the Ohio Constitution). {¶ 34} In general, delay is deemed "presumptively prejudicial" as it approaches one year.

2013Doggett v. United States, 505 U.S. 647 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 (1992), fn.1; State v. Selvage, 80 Ohio St.3d 465, 468 , 687 N.E.2d 433 (1997).

52003–2013
Kohmescher v. Kroger Co. green
ohio · 1991
2 sentences

2003The Barker test for establishing a prima facie cause of action in an age discrimination case was a direct adaptation of the evidentiary standards and guidelines established by the United States Supreme Court in McDonnell Douglas Corp. v. Green (1973), 411 U.S. 792 , 802 ; Kohmesher , 61 Ohio St.3d 501 . {¶ 42} In McDonnell Douglas Corp. v. Green , 411 U.S. 792 , the United States Supreme Court established a flexible formula to ferret out impermissible discrimination in the hiring, firing, promoting and demoting of employees.

2003The Barker test for establishing a prima facie cause of action in an age discrimination case was a direct adaptation of the evidentiary standards and guidelines established by the United States Supreme Court in McDonnell Douglas Corp. v. Green (1973), 411 U.S. 792 , 802 ; Kohmesher , 61 Ohio St.3d 501 . {¶ 42} In McDonnell Douglas Corp. v. Green , 411 U.S. 792 , the United States Supreme Court established a flexible formula to ferret out impermissible discrimination in the hiring, firing, promoting and demoting of employees.

51996–2003
State v. Miller, Unpublished Decision (2-10-2005) green
ohioctapp · 2005
2 sentences

2016Doggett v. United States, 505 U.S. 647 (1992); Miller, 2005-Ohio-518, at ¶ 11 .

2016Doggett v. United States, 505 U.S. 647 (1992); Miller, 2005-Ohio-518, at ¶ 11 .

42012–2016
State v. Luck green
ohio · 1984
2 sentences

2008Though some might express them in different ways, we identify four such factors: Length of delay, the reason for the delay, the defendant's assertions of his right, and prejudice to the defendant." (Footnotes omitted.) See, also, State v. Luck (1984), 15 Ohio St.3d 150 (the standard to be applied under the Ohio Constitution is the same as that applied to the Sixth Amendment) and State v. Davis (1976), 46 Ohio St.2d 444 (applying the Barker test in Ohio). {¶ 16} The Court labeled the first factor, the length of the delay, a "triggering mechanism," because "[u]ntil there is some delay which is p

2008Though some might express them in different ways, we identify four such factors: Length of delay, the reason for the delay, the defendant's assertions of his right, and prejudice to the defendant." (Footnotes omitted.) See, also, State v. Luck (1984), 15 Ohio St.3d 150 (the standard to be applied under the Ohio Constitution is the same as that applied to the Sixth Amendment) and State v. Davis (1976), 46 Ohio St.2d 444 (applying the Barker test in Ohio). {¶ 16} The Court labeled the first factor, the length of the delay, a "triggering mechanism," because "[u]ntil there is some delay which is p

32004–2014
O'CONNOR v. Consolidated Coin Caterers Corp. green
scotus · 1996
2 sentences

2001Id. {¶ 17} Keener correctly argues that the United States Supreme Court, in O’Connor v. Consolidated Coin Caterers Corp. (1996), 517 U.S. 308 , 116 S.Ct. *326 1307, 134 L.Ed.2d 433 , modified the fourth element of the Barker analysis as it applies to age discrimination cases.

2001Id. {¶ 17} Keener correctly argues that the United States Supreme Court, in O’Connor v. Consolidated Coin Caterers Corp. (1996), 517 U.S. 308 , 116 S.Ct. *326 1307, 134 L.Ed.2d 433 , modified the fourth element of the Barker analysis as it applies to age discrimination cases.

32001–2004
Barker v. Scovill, Inc. green
ohio · 1983
2 sentences

2001Id. {¶ 17} Keener correctly argues that the United States Supreme Court, in O’Connor v. Consolidated Coin Caterers Corp. (1996), 517 U.S. 308 , 116 S.Ct. *326 1307, 134 L.Ed.2d 433 , modified the fourth element of the Barker analysis as it applies to age discrimination cases.

2001Id. {¶ 17} Keener correctly argues that the United States Supreme Court, in O’Connor v. Consolidated Coin Caterers Corp. (1996), 517 U.S. 308 , 116 S.Ct. *326 1307, 134 L.Ed.2d 433 , modified the fourth element of the Barker analysis as it applies to age discrimination cases.

32001–2003
State v. Meeker green
ohio · 1971
2 sentences

2022II. {¶4} The state’s sole assignment of error maintains that the eight-and-a-half- month delay in initiating the prosecution against Mr. Mughni did not run afoul of his right 2 OHIO FIRST DISTRICT COURT OF APPEALS to a speedy trial under the Barker factors, described in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972). {¶5} “Both the United States and the Ohio Constitution guarantee the right to a speedy trial.” State v. Gage, 2018-Ohio-480 , 104 N.E.3d 994, ¶ 25 (1st Dist.), citing State v. Meeker, 26 Ohio St.2d 9 , 268 N.E.2d 589 (1971), paragraph one of the syllabus.

2022II. {¶4} The state’s sole assignment of error maintains that the eight-and-a-half- month delay in initiating the prosecution against Mr. Mughni did not run afoul of his right 2 OHIO FIRST DISTRICT COURT OF APPEALS to a speedy trial under the Barker factors, described in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972). {¶5} “Both the United States and the Ohio Constitution guarantee the right to a speedy trial.” State v. Gage, 2018-Ohio-480 , 104 N.E.3d 994, ¶ 25 (1st Dist.), citing State v. Meeker, 26 Ohio St.2d 9 , 268 N.E.2d 589 (1971), paragraph one of the syllabus.

22022–2025
State v. Hull green
ohio · 2006
2 sentences

2024The Barker factors are “(1) the length of the delay; (2) the reason for the delay; (3) the defendant’s assertion of his speedy trial right; and (4) prejudice to the defendant.” State v. Hull, 110 Ohio St.3d 183 , 2006-Ohio-4252 , 852 N.E.2d 706, ¶ 22 , citing Barker at 530 .

2024The Barker factors are “(1) the length of the delay; (2) the reason for the delay; (3) the defendant’s assertion of his speedy trial right; and (4) prejudice to the defendant.” State v. Hull, 110 Ohio St.3d 183 , 2006-Ohio-4252 , 852 N.E.2d 706, ¶ 22 , citing Barker at 530 .

22022–2024
State v. Taylor green
ohio · 2002
2 sentences

2020See Gaston at ¶32. {¶108} “In Barker, supra, the United States Supreme Court ‘set forth a balancing test that considers the following factors to determine whether trial delays are reasonable under the Sixth and Fourteenth Amendments to the United States Constitution: “Length of delay, the reason for the delay, the defendant's assertion of his right, and prejudice to the defendant.”’” Id. at ¶34, quoting State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7017 , ¶38, quoting Barker at 530. {¶109} Construing Mr. Stuart’s motion to discharge as a formal withdrawal of his waiver, the trial court properl

2020See Gaston at ¶32. {¶108} “In Barker, supra, the United States Supreme Court ‘set forth a balancing test that considers the following factors to determine whether trial delays are reasonable under the Sixth and Fourteenth Amendments to the United States Constitution: “Length of delay, the reason for the delay, the defendant's assertion of his right, and prejudice to the defendant.”’” Id. at ¶34, quoting State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7017 , ¶38, quoting Barker at 530. {¶109} Construing Mr. Stuart’s motion to discharge as a formal withdrawal of his waiver, the trial court properl

22019–2020
State v. Taylor green
ohio · 2002
2 sentences

2020See Gaston at ¶32. {¶108} “In Barker, supra, the United States Supreme Court ‘set forth a balancing test that considers the following factors to determine whether trial delays are reasonable under the Sixth and Fourteenth Amendments to the United States Constitution: “Length of delay, the reason for the delay, the defendant's assertion of his right, and prejudice to the defendant.”’” Id. at ¶34, quoting State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7017 , ¶38, quoting Barker at 530. {¶109} Construing Mr. Stuart’s motion to discharge as a formal withdrawal of his waiver, the trial court properl

2020See Gaston at ¶32. {¶108} “In Barker, supra, the United States Supreme Court ‘set forth a balancing test that considers the following factors to determine whether trial delays are reasonable under the Sixth and Fourteenth Amendments to the United States Constitution: “Length of delay, the reason for the delay, the defendant's assertion of his right, and prejudice to the defendant.”’” Id. at ¶34, quoting State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7017 , ¶38, quoting Barker at 530. {¶109} Construing Mr. Stuart’s motion to discharge as a formal withdrawal of his waiver, the trial court properl

22019–2020
State v. Veney green
ohio · 2008
2 sentences

2016Barker, 2010-Ohio-3067 , 2010 WL 2638515 , ¶ 15, quoting Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621, ¶ 29 .

2016Barker, 2010-Ohio-3067 , 2010 WL 2638515 , ¶ 15, quoting Veney, 120 Ohio St.3d 176 , 2008-Ohio-5200 , 897 N.E.2d 621, ¶ 29 .

22011–2016
State v. Bailey, Unpublished Decision (10-14-2005) green
ohioctapp · 2005
2 sentences

2013Montgomery No. 20764, 2005-Ohio-5506 ], our review of the Barker factors leads us to conclude that Owens’ Sixth Amendment speedy trial right was not violated.

2013Montgomery No. 20764, 2005-Ohio-5506 ], our review of the Barker factors leads us to conclude that Owens’ Sixth Amendment speedy trial right was not violated.

22011–2013
State v. Smith, Unpublished Decision (12-24-2003) green
ohioctapp · 2003
2 sentences

2008Indeed, "[t]o condone `prolonged and unjustifiable delays in prosecution would both penalize many defendants for the state's fault and simply encourage the government to gamble with the interests of criminal suspects assigned a low prosecutorial priority.'" Smith , 2003-Ohio-7076 , ¶ 19 , quoting Doggett , supra, at 657 . {¶ 43} Accordingly, applying the Barker factors, we find that the trial court erred in denying Barnes' motion to dismiss. {¶ 44} Barnes' sole assignment of error is sustained. {¶ 45} Conviction vacated and appellant discharged.

2008Indeed, "[t]o condone `prolonged and unjustifiable delays in prosecution would both penalize many defendants for the state's fault and simply encourage the government to gamble with the interests of criminal suspects assigned a low prosecutorial priority.'" Smith , 2003-Ohio-7076 , ¶ 19 , quoting Doggett , supra, at 657 . {¶ 43} Accordingly, applying the Barker factors, we find that the trial court erred in denying Barnes' motion to dismiss. {¶ 44} Barnes' sole assignment of error is sustained. {¶ 45} Conviction vacated and appellant discharged.

22008–2013
State v. Keaton green
ohioctapp · 2017
12025–2025
State v. King green
ohioctapp · 2009
12025–2025
State v. Rogers green
ohioctapp · 2019
12024–2024
State v. Mughni green
ohioctapp · 2022
12023–2023
State v. Williams green
ohioctapp · 2020
12022–2022
State v. Squillace green
ohioctapp · 2016
12021–2021
Duncan v. Louisiana green
scotus · 1968
12019–2019
State v. Boyd, Unpublished Decision (3-16-2005) neutral
ohioctapp · 2005
12019–2019
State v. Lomax green
ohio · 2007
12019–2019
United States v. Marion green
scotus · 1971
12018–2018
State v. Childs green
ohio · 1968
12016–2016
State v. Awan green
ohio · 1986
12016–2016
State v. Quarterman (Slip Opinion) green
ohio · 2014
12016–2016
State v. Pilgrim green
ohioctapp · 2009
12014–2014
State v. Ladd green
ohio · 1978
12014–2014
State v. Gettys green
ohioctapp · 1976
12014–2014
State v. Sellers, 08ap-810 (5-12-2009) green
ohioctapp · 2009
12014–2014
State v. Wells green
ohioctapp · 2013
12014–2014
State v. Johnson green
ohioctapp · 2012
12013–2013
State v. Myers green
ohio · 2002
12011–2011
State v. Hilyard, Unpublished Decision (9-7-2005) green
ohioctapp · 2005
12009–2009
State v. Walker, 06ap-810 (9-11-2007) green
ohioctapp · 2007
12008–2008
Shirley J. MITCHELL, Plaintiff-Appellant, v. TOLEDO HOSPITAL, Defendant-Appellee green
ca6 · 1992
12007–2007
United States v. Lovasco green
scotus · 1977
12007–2007
Rabinovitch v. Nyquist green
scotus · 1977
12007–2007
Seasons Coal Co. v. City of Cleveland green
ohio · 1984
12005–2005

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2945.71 (59) OH § Ohio Rev. Code § 2945.72 (40) OH § Ohio Rev. Code § 2945.73 (25) OH § Ohio Rev. Code § 2929.14 (12) OH § Ohio Rev. Code § 2905.01 (9) OH § Ohio Rev. Code § 2925.11 (9) OH § Ohio Rev. Code § 2941.401 (9) OH § Ohio Rev. Code § 2953.08 (8) OH § Ohio Rev. Code § 2911.01 (7) OH § Ohio Rev. Code § 2929.11 (7) OH § Ohio Rev. Code § 2913.02 (6) OH § Ohio Rev. Code § 2923.13 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 479 (1995–2026) MS 238 (1986–2026) NM 227 (1987–2026) GA 146 (1976–2026) OH 129 (1985–2026) TN 91 (1987–2026) AL 75 (1977–2026) CA 69 (1980–2026) LA 68 (1983–2025) NJ 47 (1999–2026) WA 45 (2009–2026) KS 42 (1979–2026) NC 41 (1993–2026) MI 40 (2006–2026) MT 40 (1975–2020) IL 39 (1989–2025) ID 38 (1981–2025) WY 38 (1989–2023) IN 32 (1980–2020) MO 29 (1979–2025) DE 28 (1987–2026) PA 28 (1976–2025) MN 27 (1986–2025) MD 26 (1975–2024) CO 25 (1975–2026) KY 23 (1978–2024) VT 21 (1983–2025) VA 19 (1990–2025) RI 18 (1967–2015) WI 17 (1990–2026) UT 16 (1986–2026) NH 16 (1985–2022) AZ 16 (1982–2026) HI 14 (1981–2025) DC 13 (1977–2012) FL 12 (1982–2024) ME 11 (1981–2025) MA 9 (1982–2025) SC 9 (2009–2026) VI 8 (2010–2026) CT 8 (1987–2018) OR 8 (1977–2021) ND 8 (1994–2021) NV 8 (1983–2020) AK 6 (1991–2024) NE 5 (1999–2019) OK 5 (1994–2023) SD 3 (1994–2026) IA 3 (2001–2019) NY 3 (1896–2018) AR 2 (2004–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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