prima facie speedy trial violation (Ohio) · Go Syfert
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prima facie speedy trial violation in Ohio

15 Ohio opinions name it 1 courts 2008–2026 13 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 (7)

CaseFollowedCited
State v. Butchergreen
ohio · 1986 · cited in 13 Ohio opinions naming this issue, 2020–2026
2 sentences

2026“A defendant establishes a prima facie speedy trial violation when his motion [to dismiss] reveals that a trial did not occur within the time period prescribed by R.C. 2945.71.” State v. Hill, 2020-Ohio-2958, ¶ 6 (2d Dist.), citing State v. Butcher, 27 Ohio St.3d 28, 31 (1986).

2025“A defendant establishes a prima facie speedy trial violation when his motion [to dismiss] reveals that a trial did not occur within the time period prescribed by R.C. 2945.71.” State v. Hill, 2020-Ohio-2958, ¶ 6 (2d Dist.), citing State v. Butcher, 27 Ohio St.3d 28, 31 (1986).

1013
State v. Hillgreen
ohioctapp · 2020 · cited in 10 Ohio opinions naming this issue, 2024–2026
2 sentences

2026“A defendant establishes a prima facie speedy trial violation when his motion [to dismiss] reveals that a trial did not occur within the time period prescribed by R.C. 2945.71.” State v. Hill, 2020-Ohio-2958, ¶ 6 (2d Dist.), citing State v. Butcher, 27 Ohio St.3d 28, 31 (1986).

2025“A defendant establishes a prima facie speedy trial violation when his motion [to dismiss] reveals that a trial did not occur within the time period prescribed by R.C. 2945.71.” State v. Hill, 2020-Ohio-2958, ¶ 6 (2d Dist.), citing State v. Butcher, 27 Ohio St.3d 28, 31 (1986).

910
State v. Wagnergreen
ohioctapp · 2021 · cited in 5 Ohio opinions naming this issue, 2024–2025
2 sentences

2025“If a defendant ‘establishes a prima facie case of a violation of his right to a speedy trial, the burden then shifts to the State’ to demonstrate either that the statutory limit was not exceeded, or that the State’s time to bring the defendant to trial was properly extended.” State v. Wagner, 2021-Ohio-1671, ¶ 12 (2d Dist.), quoting State v. Nichols, 2005-Ohio-1771, ¶ 11 (5th Dist.), citing Butcher at 30- 31. i. Case Nos. 21-CR-739 and 22-CR-57 {¶ 44} According to Little, his statutory speedy trial time in Case Nos. 21-CR-739 and 22-CR-57 was not extended by the December 2022 mistrial because

2025“If a defendant ‘establishes a prima facie case of a violation of his right to a speedy trial, the burden then shifts to the State’ to demonstrate either that the statutory limit was not exceeded, or that the State’s time to bring the defendant to trial was properly extended.” State v. Wagner, 2021-Ohio-1671, ¶ 12 (2d Dist.), quoting State v. Nichols, 2005- Ohio-1771, ¶ 11 (5th Dist.).

55
State v. Nichols, Unpublished Decision (4-13-2005)green
ohioctapp · 2005 · cited in 4 Ohio opinions naming this issue, 2024–2025
2 sentences

2025“If a defendant ‘establishes a prima facie case of a violation of his right to a speedy trial, the burden then shifts to the State’ to demonstrate either that the statutory limit was not exceeded, or that the State’s time to bring the defendant to trial was properly extended.” State v. Wagner, 2021-Ohio-1671, ¶ 12 (2d Dist.), quoting State v. Nichols, 2005-Ohio-1771, ¶ 11 (5th Dist.), citing Butcher at 30- 31. i. Case Nos. 21-CR-739 and 22-CR-57 {¶ 44} According to Little, his statutory speedy trial time in Case Nos. 21-CR-739 and 22-CR-57 was not extended by the December 2022 mistrial because

2024“If a defendant ‘establishes a prima facie case of a violation of his right to a speedy trial, the burden then shifts to the State’ to demonstrate either that the statutory limit was not exceeded, or that the State’s time to bring the defendant to trial was properly extended.” State v. Wagner, 2021-Ohio-1671, ¶ 12 (2d Dist.), quoting State v. Nichols, 2005-Ohio-1771, ¶ 11 (5th Dist.), citing Butcher at 30-31 .

44
State v. Dankworthgreen
ohioctapp · 2007 · cited in 2 Ohio opinions naming this issue, 2024–2025
2 sentences

2025State v. Dankworth, 2007-Ohio-2588, ¶ 31 (2d Dist.). {¶ 86} “A defendant establishes a prima facie speedy trial violation when his motion [to dismiss] reveals that a trial did not occur within the time period prescribed by R.C. 2945.71.” State v. Hill, 2020-Ohio-2958, ¶ 6 (2d Dist.), citing State v. Butcher, 27 Ohio St.3d 28, 31 (1986).

2024State v. Dankworth, 2007-Ohio-2588, ¶ 31 (2d Dist.). {¶ 18} “A defendant establishes a prima facie speedy trial violation when his motion [to dismiss] reveals that a trial did not occur within the time period prescribed by R.C. 2945.71.” State v. Hill, 2020-Ohio-2958, ¶ 6 (2d Dist.), citing State v. Butcher, 27 Ohio St.3d 28, 31 (1986).

22
State v. Brooksgreen
ohioctapp · 2018 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024See Brooks, supra, at ¶ 24 ; State v. Smith, 2017-Ohio-7864 , ¶ 21 (4th Dist.), citing State v. Squillace, 2016-Ohio-1038, ¶ 14 (10th Dist.).

11
State v. Squillacegreen
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024See Brooks, supra, at ¶ 24 ; State v. Smith, 2017-Ohio-7864 , ¶ 21 (4th Dist.), citing State v. Squillace, 2016-Ohio-1038, ¶ 14 (10th Dist.).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
State v. Belville green
ohio · 2022
1 sentence

2026However, that time period can be extended or tolled by any of the several events listed under R.C. 2945.72(A) through (J). {¶ 24} Pursuant to R.C. 2945.72(E), speedy-trial time is tolled for “[a]ny period of delay necessitated by reason of a plea in bar or abatement, motion, proceeding, or action made or instituted by the accused.” To qualify as a tolling event under R.C. 2945.72(E), “all that the statute requires is that the delay be necessitated by the defendant’s action.” State v. Belville, 2022-Ohio-3879, ¶ 31 .

12026–2026
State v. Ramey green
ohio · 2012
1 sentence

2025It is well established that the 270-day time limit for bringing a defendant to trial can be extended or tolled for any of the reasons listed under R.C. 2945.72(A) through (J). {¶ 23} It is also well established that “[a] criminal defendant may waive speedy trial rights.” (Citations omitted.) State v. Ramey, 2012-Ohio-2904, ¶ 18 .

12025–2025
State v. Hiatt green
ohioctapp · 1997
1 sentence

2008"We accept the facts as found by the trial court on some competent, credible evidence, but freely review the application of the law to the facts." Id., citing Hiatt at 261 . *Page 26 {¶ 116} Mr. Jackson fails to allege a prima facie speedy trial violation as he did not timely respond to the state's reciprocal discovery request.

12008–2008

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2945.71 (14) OH § Ohio Rev. Code § 2945.72 (14) OH § Ohio Rev. Code § 2945.73 (7) OH § Ohio Rev. Code § 2945.75 (6) OH § Ohio Rev. Code § 2923.13 (5) OH § Ohio Rev. Code § 2925.11 (4)

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

OH 15 (2008–2026) DC 2 (1981–1983) MD 2 (2002–2008)

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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