speedy trial claim (Ohio) · Go Syfert
← Ohio issues

speedy trial claim in Ohio

496 Ohio opinions name it 9 courts 1978–2026 144 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 (46)

CaseFollowedCited
City of Brecksville v. Cookgreen
ohio · 1996 · cited in 143 Ohio opinions naming this issue, 1998–2026
2 sentences

2024“Furthermore, when reviewing the Lawrence App. No. 23CA31 12 legal issues presented in a speedy trial claim, we must strictly construe the relevant statutes against the state.” Id., citing Brecksville v. Cook, 75 Ohio St.3d 53, 57 (1996).

2021“Furthermore, when reviewing the legal issues presented in a speedy trial claim, we must strictly construe the relevant statutes against the state.” Id., citing Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 661 N.E.2d 706 (1996). {¶12} Here, the trial court initially issued a judgment entry simply granting the motion to dismiss, without including any findings of facts.

50143
State v. Butchergreen
ohio · 1986 · cited in 16 Ohio opinions naming this issue, 2007–2026
2 sentences

2023Boyd relies on State v. Butcher, 27 Ohio St.3d 28 , 500 N.E.2d 1368 (1986), to allege that once a defendant makes a prima facie case of a speedy trial violation, the burden of production shifts to the -17- State to establish justification for the extension of speedy trial time.

2023Boyd relies on State v. Butcher, 27 Ohio St.3d 28 , 500 N.E.2d 1368 (1986), to allege that once a defendant makes a prima facie case of a speedy trial violation, the burden of production shifts to the -17- State to establish justification for the extension of speedy trial time.

916
State v. Mastersgreen
ohioctapp · 2007 · cited in 15 Ohio opinions naming this issue, 2009–2022
2 sentences

2012State v. Jenkins, 2011–Ohio–837 at ¶ 15, Cuyahoga App. No. 95006, citing State v. Masters, 172 Ohio App.3d 666 , 2007–Ohio–4229, 876 N.E.2d 1007 . {¶26} A speedy-trial claim involves a mixed question of law and fact.

2012State v. Jenkins, 2011–Ohio–837 at ¶ 15, Cuyahoga App. No. 95006, citing State v. Masters, 172 Ohio App.3d 666 , 2007–Ohio–4229, 876 N.E.2d 1007 . {¶26} A speedy-trial claim involves a mixed question of law and fact.

715
Brecksville v. Cookgreen
ohio · 1996 · cited in 28 Ohio opinions naming this issue, 2002–2026
2 sentences

2026Brecksville v. Cook, 1996-Ohio-171, ¶ 15 .

2011“Furthermore, when reviewing the legal issues presented in a speedy trial claim, we must strictly construe the relevant statutes against the state.” Id. citing Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 1996-Ohio-171 .

628
Barker v. Wingogreen
scotus · 1972 · cited in 27 Ohio opinions naming this issue, 1995–2026
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.

2023“Generally, a delay that approaches one year is presumptively prejudicial.” Long at ¶ 14 . {¶9} “Once the accused makes a showing of presumptive prejudice, courts must then consider the second prong of the speedy trial analysis, which is a ‘balancing test in which the conduct of both the prosecution and the defendant are weighed.’” McCain at ¶ 12, quoting Barker, 407 U.S. at 530 .

627
Doggett v. United Statesgreen
scotus · 1992 · cited in 26 Ohio opinions naming this issue, 1995–2026
2 sentences

2026“The factors include: (1) the length of the delay ‘between accusation and trial’; (2) the reason for the delay; (3) the defendant’s assertion, if any, of his right to a speedy trial; and (4) the prejudice, if any, to the defendant.” Id., citing Doggett v. United States, 505 U.S. 647, 651 (1992), and State v. Adams, 2015-Ohio-3954 , ¶ 88. {¶ 12} “None of the factors is controlling because a ‘balancing test necessarily compels’ a court to evaluate an alleged speedy trial violation ‘on an ad hoc basis,’ meaning that the court must consider the totality of the circumstances.” Id. at ¶ 15, quoting

2025“The factors include: (1) the length of the delay ‘between accusation and trial’; (2) the reason for the delay; (3) the 20 defendant’s assertion, if any, of his right to a speedy trial; and (4) the prejudice, if any, to the defendant.” Id., citing Doggett v. United States, 505 U.S. 647, 651 (1992), and State v. Adams, 2015-Ohio-3954 , ¶ 88. {¶ 58} “None of the factors is controlling because a ‘balancing test necessarily compels’ a court to evaluate an alleged speedy trial violation ‘on an ad hoc basis,’ meaning that the court must consider the totality of the circumstances.” Id. at ¶ 15, quoti

426
State v. Pachaygreen
ohio · 1980 · cited in 21 Ohio opinions naming this issue, 2001–2024
2 sentences

2023"The statutory speedy trial provisions, R.C. 2945.71 et seq., constitute a rational effort to enforce the constitutional right to a public speedy trial of an accused charged with the commission of a felony or a misdemeanor and shall be strictly enforced by the courts of this state." State v. Pachay, 64 Ohio St.2d 218 , 416 N.E.2d 589 , syllabus (1980). {¶ 8} A speedy-trial claim involves a mixed question of law and fact.

2023"The statutory speedy trial provisions, R.C. 2945.71 et seq., constitute a rational effort to enforce the constitutional right to a public speedy trial of an accused charged with the commission of a felony or a misdemeanor and shall be strictly enforced by the courts of this state." State v. Pachay, 64 Ohio St.2d 218 , 416 N.E.2d 589 , syllabus (1980). {¶ 8} A speedy-trial claim involves a mixed question of law and fact.

421
State v. Leegreen
ohioctapp · 2024 · cited in 4 Ohio opinions naming this issue, 2024–2026
2 sentences

2026However, “the length of the delay is a particularly important factor as it ‘is to some extent a triggering mechanism.’” State v. Lee, 2024-Ohio-1802, ¶ 9 (2d Dist.), quoting Barker at 530 .

2025“However, . . . the length of the delay is a particularly important factor as it ‘is to some extent a triggering mechanism.’” State v. Lee, 2024-Ohio-1802, ¶ 9 (2d Dist.), quoting Barker at 530 .

44
State v. Larkin, Unpublished Decision (6-21-2005)green
ohioctapp · 2005 · cited in 17 Ohio opinions naming this issue, 2006–2025
2 sentences

2024Id. {¶19} When reviewing the legal issues presented in a speedy-trial claim, we must strictly construe the relevant statutes against appellee.

2021Id. {¶21} When reviewing the legal issues presented in a speedy-trial claim, we must strictly construe the relevant statutes against appellee.

317
State v. Sanchezgreen
ohio · 2006 · cited in 8 Ohio opinions naming this issue, 2007–2024
2 sentences

2024State v. Sanchez, 110 Ohio St.3d 274 , 2006-Ohio-4478 , ¶ 8. {¶ 39} Here, Blacker was arrested for the felonious assault of Betsy on March 5, 2021.

2022See also State v. Sanchez, 110 Ohio St.3d 274 , 2006-Ohio-4478 , 853 N.E.2d 283 , ¶ 8. {¶ 18} When the trial court sua sponte grants a continuance under R.C. 2945.72(H), the court “must enter the order of continuance and the reasons therefor by journal entry prior to the expiration of the time limit prescribed in R.C. 2945.71 for bringing a defendant to trial.” State v. Mincy, 2 Ohio St.3d 6 , 441 N.E.2d 571 (1982), syllabus. {¶ 19} “When an accused demonstrates a prima facie case of a speedy trial violation by showing that the trial was held beyond the time limit set by the statute, the burde

38
State v. Rileygreen
ohioctapp · 2005 · cited in 7 Ohio opinions naming this issue, 2006–2012
2 sentences

2007The Ohio General Assembly enacted the provisions in R.C. 2945.71 et seq. in an effort to prescribe “ ‘reasonable speedy trial periods consistent with these constitutional provisions.’ ” Riley at 735, 2005-Ohio-4337 , 834 N.E.2d 887 , quoting State v. O’Brien (1987), 34 Ohio St.3d 7, 8 , 516 N.E.2d 218 . {¶ 34} When reviewing the legal issues presented in a speedy-trial claim, we must strictly construe the relevant statutes against the state.

2007The Ohio General Assembly enacted the provisions in R.C. 2945.71 et seq. in an effort to prescribe “ ‘reasonable speedy trial periods consistent with these constitutional provisions.’ ” Riley at 735, 2005-Ohio-4337 , 834 N.E.2d 887 , quoting State v. O’Brien (1987), 34 Ohio St.3d 7, 8 , 516 N.E.2d 218 . {¶ 34} When reviewing the legal issues presented in a speedy-trial claim, we must strictly construe the relevant statutes against the state.

37
State v. Dankworthgreen
ohioctapp · 2007 · cited in 4 Ohio opinions naming this issue, 2014–2020
34
State v. Maischgreen
ohioctapp · 2007 · cited in 4 Ohio opinions naming this issue, 2010–2019
34
State v. Knottgreen
ohioctapp · 2024 · cited in 3 Ohio opinions naming this issue, 2025–2026
33
State v. Harrisgreen
ohioctapp · 2023 · cited in 3 Ohio opinions naming this issue, 2025–2025
33
State v. Gray, 20980 (8-31-2007)green
ohioctapp · 2007 · cited in 3 Ohio opinions naming this issue, 2025–2025
33
State v. Long (Slip Opinion)green
ohio · 2020 · cited in 36 Ohio opinions naming this issue, 2021–2026
2 sentences

2025R.C. 2945.71(E). ”Review of a speedy-trial claim involves a mixed question of law and fact.” State v. Long, 2020-Ohio-5363, ¶ 15 .

2025“If the defendant can make this showing, the burden shifts to the State to establish that some exception[s] applied to toll the time and to make the trial timely.” Gray at ¶ 15, citing State v. Price, 122 Ohio App.3d 65, 68 (10th Dist. 1997). {¶ 21} “Review of a speedy-trial claim involves a mixed question of law and fact.” State v. Long, 2020-Ohio-5363, ¶ 15 .

236
State v. O'Briengreen
ohio · 1987 · cited in 19 Ohio opinions naming this issue, 2000–2026
2 sentences

2026O'Brien, 34 Ohio St.3d at 9-10 . {¶67} Accordingly, where there is a proper revocation of a time waiver, the statutory speedy trial time does not then reactivate; instead, the question for a speedy trial claim becomes whether the delay post-revocation was constitutionally unreasonable considering the length of delay, the reason for the delay, the defendant's assertion of his right, and the prejudice to the defendant.

2023After making an express written speedy trial waiver, the defendant cannot assert a speedy trial violation unless he “files a formal written objection to any further continuances and makes a demand for trial, following which the state must bring him to trial within a reasonable time.” Id.

219
State v. Barnes, 90847 (10-23-2008)green
ohioctapp · 2008 · cited in 8 Ohio opinions naming this issue, 2011–2026
2 sentences

2011Appellant was denied speedy trial rights due the unreasonable delay by State to respond to the discovery request.” {¶ 42} When an appellate court reviews an allegation of a speedy trial violation, it “should apply a de novo standard of review to the legal issues but afford great deference to any findings of fact made by the trial court.” State v. Barnes, Cuyahoga App. No. 90847, 2008-Ohio-5472, ¶17 . {¶ 43} R.C. 2945.71(C)(2) requires the state to bring a defendant accused of committing a felony to trial within 270 days after his arrest. “[E]ach day during which the accused is held in jail in

2011Speedy Trial {¶ 18} In the first assigned error, Shabazz argues the trial court erred when it denied his motion to dismiss for a violation of his right to a speedy trial. {¶ 19} When an appellate court reviews an allegation of a speedy trial violation, it “should apply a de novo standard of review to the legal issues but afford great deference to any findings of fact made by the trial court.” State v. Barnes, Cuyahoga App. No. 90847, 2008-Ohio-5472, ¶17 . {¶ 20} The Sixth and Fourteenth Amendments to the United States Constitution, and Section 10, Article I of the Ohio Constitution, guarantee

28
State v. Wagnergreen
ohioctapp · 2021 · cited in 4 Ohio opinions naming this issue, 2024–2026
2 sentences

2026“The factors include: (1) the length of the delay ‘between accusation and trial’; (2) the reason for the delay; (3) the defendant’s assertion, if any, of his right to a speedy trial; and (4) the prejudice, if any, to the defendant.” Id., citing Doggett v. United States, 505 U.S. 647, 651 (1992), and State v. Adams, 2015-Ohio-3954 , ¶ 88. {¶ 12} “None of the factors is controlling because a ‘balancing test necessarily compels’ a court to evaluate an alleged speedy trial violation ‘on an ad hoc basis,’ meaning that the court must consider the totality of the circumstances.” Id. at ¶ 15, quoting

2025“The -10- factors include: (1) the length of the delay ‘between accusation and trial’; (2) the reason for the delay; (3) the defendant’s assertion, if any, of his right to a speedy trial; and (4) the prejudice, if any, to the defendant.” (Citations omitted.) State v. Wagner, 2021-Ohio-1671, ¶ 14 (2d Dist.) {¶ 26} “None of the factors is controlling because a ‘balancing test necessarily compels’ a court to evaluate an alleged speedy trial violation ‘on an ad hoc basis,’ meaning that the court must consider the totality of the circumstances.” Id. at ¶ 15, quoting Barker at 530 .

24
State v. Kerbygreen
ohioctapp · 2005 · cited in 3 Ohio opinions naming this issue, 2017–2025
23
State v. Smithgreen
ohioctapp · 2023 · cited in 2 Ohio opinions naming this issue, 2026–2026
22
State v. Lovettgreen
ohioctapp · 2022 · cited in 2 Ohio opinions naming this issue, 2025–2025
22
State v. Conkright, Unpublished Decision (9-28-2007)green
ohioctapp · 2007 · cited in 2 Ohio opinions naming this issue, 2025–2025
22
State v. Smithgreen
ohio · 1985 · cited in 2 Ohio opinions naming this issue, 2025–2025
22
State v. Kendallgreen
ohioctapp · 2025 · cited in 2 Ohio opinions naming this issue, 2025–2025
22
State v. Wilsongreen
ohioctapp · 2019 · cited in 2 Ohio opinions naming this issue, 2025–2025
22
State v. Blackgreen
ohioctapp · 2019 · cited in 2 Ohio opinions naming this issue, 2025–2025
22
State v. Searsgreen
ohioctapp · 2005 · cited in 2 Ohio opinions naming this issue, 2023–2024
22
State v. Cimpayegreen
ohioctapp · 2020 · cited in 2 Ohio opinions naming this issue, 2022–2023
22
State v. Highgreen
ohioctapp · 2001 · cited in 12 Ohio opinions naming this issue, 2003–2024
2 sentences

2007Furthermore, when reviewing the legal issues presented in a speedy trial claim, an appellate court must strictly construe the relevant statutes against the state." (Internal citations omitted.) Id. at 241-242 .

2003Furthermore, when reviewing the legal issues presented in a speedy trial claim, an appellate court must strictly construe the relevant statutes against the state.” (Internal citations omitted.) Id. at 241-242 , 757 N.E.2d 1176 . {¶ 10} R.C. 2945.71(C)(2) requires that anyone charged with a felony be brought to trial within 270 days of arrest.

112
State v. Browngreen
ohioctapp · 1998 · cited in 10 Ohio opinions naming this issue, 2004–2024
2 sentences

2024“Furthermore, when reviewing the Lawrence App. No. 23CA31 12 legal issues presented in a speedy trial claim, we must strictly construe the relevant statutes against the state.” Id., citing Brecksville v. Cook, 75 Ohio St.3d 53, 57 (1996).

2021“Furthermore, when reviewing the legal issues presented in a speedy trial claim, we must strictly construe the relevant statutes against the state.” Id., citing Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 661 N.E.2d 706 (1996). {¶12} Here, the trial court initially issued a judgment entry simply granting the motion to dismiss, without including any findings of facts.

110
State v. Pricegreen
ohioctapp · 1997 · cited in 8 Ohio opinions naming this issue, 2000–2025
2 sentences

2025“If the defendant can make this showing, the burden shifts to the State to establish that some exception[s] applied to toll the time and to make the trial timely.” Gray at ¶ 15, citing State v. Price, 122 Ohio App.3d 65, 68 (10th Dist. 1997). {¶ 21} “Review of a speedy-trial claim involves a mixed question of law and fact.” State v. Long, 2020-Ohio-5363, ¶ 15 .

2025“If the defendant can make this showing, the burden shifts to the State to establish that some exception[s] applied to toll the time and to make the trial timely.” Gray at ¶ 15, citing State v. Price, 122 Ohio App.3d 65, 68 (10th Dist. 1997). {¶ 21} “Review of a speedy-trial claim involves a mixed question of law and fact.” State v. Long, 2020-Ohio-5363, ¶ 15 .

18
State v. Westerfieldgreen
ohioctapp · 2018 · cited in 5 Ohio opinions naming this issue, 2021–2025
2 sentences

2025According to Walker’s calculation, “the required date to be brought to trial would be December 20, 2023.” (Appellant’s Brief at 6). 1 The trial court filed its judgment entry of sentence on June 25, 2024. -4- Case No. 2-24-05 Standard of Review {¶14} “Appellate review of a trial court’s decision on a motion to dismiss for a speedy-trial violation involves a mixed question of law and fact.” State v. Westerfield, 2018-Ohio-2139, ¶ 17 (3d Dist.). “‘Accordingly, a reviewing court must give due deference to the trial court’s findings of fact if they are supported by competent, credible evidence but

2024Crawford No. 3-17-15, 2018-Ohio-2139, ¶ 17 .

15
State v. Kinggreen
ohio · 1994 · cited in 5 Ohio opinions naming this issue, 2004–2017
2 sentences

2017To be effective, the defendant’s speedy trial waiver must also “be expressed in writing or made in open court on the record.” State v. King, 70 Ohio St.3d 158 , 637 N.E.2d 903 (1994), syllabus. {¶11} As previously stated, the court explained the nature of the charges pending against Nagy as well as the possible penalties attendant to the charges.

2017To be effective, the defendant’s speedy trial waiver must also “be expressed in writing or made in open court on the record.” State v. King, 70 Ohio St.3d 158 , 637 N.E.2d 903 (1994), syllabus. {¶11} As previously stated, the court explained the nature of the charges pending against Nagy as well as the possible penalties attendant to the charges.

15
State v. Adams (Slip Opinion)green
ohio · 2015 · cited in 4 Ohio opinions naming this issue, 2016–2026
2 sentences

2026“The factors include: (1) the length of the delay ‘between accusation and trial’; (2) the reason for the delay; (3) the defendant’s assertion, if any, of his right to a speedy trial; and (4) the prejudice, if any, to the defendant.” Id., citing Doggett v. United States, 505 U.S. 647, 651 (1992), and State v. Adams, 2015-Ohio-3954 , ¶ 88. {¶ 12} “None of the factors is controlling because a ‘balancing test necessarily compels’ a court to evaluate an alleged speedy trial violation ‘on an ad hoc basis,’ meaning that the court must consider the totality of the circumstances.” Id. at ¶ 15, quoting

2025“The factors include: (1) the length of the delay ‘between accusation and trial’; (2) the reason for the delay; (3) the 20 defendant’s assertion, if any, of his right to a speedy trial; and (4) the prejudice, if any, to the defendant.” Id., citing Doggett v. United States, 505 U.S. 647, 651 (1992), and State v. Adams, 2015-Ohio-3954 , ¶ 88. {¶ 58} “None of the factors is controlling because a ‘balancing test necessarily compels’ a court to evaluate an alleged speedy trial violation ‘on an ad hoc basis,’ meaning that the court must consider the totality of the circumstances.” Id. at ¶ 15, quoti

14
State v. Parkergreen
ohio · 2007 · cited in 3 Ohio opinions naming this issue, 2019–2022
13
State v. Johnsongreen
ohioctapp · 2013 · cited in 3 Ohio opinions naming this issue, 2013–2022
13
State v. Gartrellgreen
ohioctapp · 2014 · cited in 3 Ohio opinions naming this issue, 2019–2022
13
State v. Thompsongreen
ohioctapp · 1994 · cited in 3 Ohio opinions naming this issue, 2005–2019
13

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 (34)

CaseCitedYears
City of Oregon v. Kohne green
ohioctapp · 1997
2 sentences

2014City of Oregon v. Kohne, 117 Ohio App.3d 179 , 690 N.E.2d 66 (1997). {¶24} Appellant was served with the arrest warrant on January 23, 2012.

2014City of Oregon v. Kohne, 117 Ohio App.3d 179 , 690 N.E.2d 66 (1997). {¶24} Appellant was served with the arrest warrant on January 23, 2012.

162002–2014
State v. Adams green
ohio · 1989
2 sentences

2022He cites State v. Adams, 43 Ohio St.3d 67, 70 , 538 N.E.2d 1025 (1989), where the Ohio Supreme Court held that a defendant’s speedy trial waiver as to an initial charge does not apply to additional charges stemming from the same set of facts brought subsequent to the execution of the waiver. {¶22} He also cites to our decision in State v. Carter, 7th Dist.

2022He cites State v. Adams, 43 Ohio St.3d 67, 70 , 538 N.E.2d 1025 (1989), where the Ohio Supreme Court held that a defendant’s speedy trial waiver as to an initial charge does not apply to additional charges stemming from the same set of facts brought subsequent to the execution of the waiver. {¶22} He also cites to our decision in State v. Carter, 7th Dist.

121995–2022
State v. Miller green
ohioctapp · 1996
2 sentences

2018In Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 661 N.E.2d 706 (1996), the court referred to its prior admonition “to strictly construe speedy trial statutes against the state.” See, also, State v. Miller, 113 Ohio App.3d 606, 608 , 681 N.E.2d 970 (11th Dist.1996).

2018In Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 661 N.E.2d 706 (1996), the court referred to its prior admonition “to strictly construe speedy trial statutes against the state.” See, also, State v. Miller, 113 Ohio App.3d 606, 608 , 681 N.E.2d 970 (11th Dist.1996).

121998–2018
State v. Cloud green
ohioctapp · 1997
2 sentences

2012Skinner, at ¶8; Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 1996-Ohio-171 , 661 N.E.2d 706 ; State v. Miller, 113 Ohio App.3d 606, 608 , 681 N.E.2d 90 (1996); State v. Cloud, 122 Ohio App.3d 626 , 702 N.E.2d 500 (1997).

2012Skinner, at ¶8; Brecksville v. Cook, 75 Ohio St.3d 53, 57 , 1996-Ohio-171 , 661 N.E.2d 706 ; State v. Miller, 113 Ohio App.3d 606, 608 , 681 N.E.2d 90 (1996); State v. Cloud, 122 Ohio App.3d 626 , 702 N.E.2d 500 (1997).

91998–2012
State v. Depue green
ohioctapp · 1994
2 sentences

2008Id., citing Brecksville v. Cook (1996), 75 Ohio St.3d 53 , 57 , 661 N.E.2d 706 , 708-709." See, also, State v. Sanchez , 110 Ohio St.3d 274 , 2006-Ohio-4478 , 853 N.E.2d 283 , at ¶ 8. {¶ 21} Here, the triple-count provision is applicable because Mitchell was held *Page 4 solely on the pending charges listed above and was held in jail in lieu of bail.

2008Id., citing Brecksville v. Cook (1996), 75 Ohio St.3d 53 , 57 , 661 N.E.2d 706 , 708-709." See, also, State v. Sanchez , 110 Ohio St.3d 274 , 2006-Ohio-4478 , 853 N.E.2d 283 , at ¶ 8. {¶ 132} Although Moore argues that his speedy trial right was violated, he offers no timeline explaining tolling dates and starting dates for speedy trial purposes. {¶ 133} The juvenile court relinquished jurisdiction over Moore and transferred him to the general division of the common pleas court by judgment entry of April 8, 2004.

92003–2008
State v. Taylor green
ohio · 2002
2 sentences

2021Clark No. 02-CA-85, 2003-Ohio-2825 , ¶ 17, and State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7071 , 781 N.E.2d 72, ¶ 37 . {¶ 56} To avoid this barrier, Lammers now contends that trial counsel was ineffective in failing to raise a speedy trial violation in the trial court.

2021Clark No. 02-CA-85, 2003-Ohio-2825 , ¶ 17, and State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7071 , 781 N.E.2d 72, ¶ 37 . {¶ 56} To avoid this barrier, Lammers now contends that trial counsel was ineffective in failing to raise a speedy trial violation in the trial court.

62007–2024
Strickland v. Washington green
scotus · 1984
2 sentences

2025Strickland v. Washington, 466 U.S. 668 (1984); State v. Lloyd, 2022-Ohio-4259, ¶ 15 . “[I]n order to demonstrate that counsel provided ineffective assistance of counsel by failing to file a motion to dismiss for speedy trial violations, the defendant must show that the motion would have been successful and the case would likely have been dismissed.” Mango at ¶ 18 , citing White at ¶ 7 . “ ‘Counsel cannot be [ineffective] for failing to file a fruitless motion.’ ” Id., quoting State v. Cottrell, 2012-Ohio-4583, ¶ 8 (4th Dist.). -6- {¶ 13} Because Jacks claims that her trial counsel was ineffect

2007Id., State v. Bradley (1989), 42 Ohio St.3d 136 . {¶ 24} Defendant does not identify when counsel should have filed a motion on a speedy trial claim at some point in time earlier than he did, arguing instead that "[a] reasonable attorney would have reached (sic) the possibility of Motion to Dismiss on speedy trial grounds when their (sic) client had been incarcerated for almost a year and a half on his charges." {¶ 25} Defendant was incarcerated for approximately sixteen months from his arrest on October 29, 2004 until his trial began.

52005–2025
State v. Taylor green
ohio · 2002
2 sentences

2024Cuyahoga No. 100898, 2014-Ohio-4475, ¶ 51 , citing State v. Taylor, 98 Ohio St.3d 27 , 2002-Ohio-7017 , 781 N.E.2d 72, ¶ 32 .

2011The Ohio Supreme Court has also held that “a defendant is bound by his counsel’s waiver of speedy trial rights, even though the waiver might have been executed without his consent.” State v. Taylor, 98 Ohio St. 3d 27 , 2002-Ohio-7017, at ¶33 . {¶6} If a speedy trial waiver does not mention a specific time period, it is unlimited in duration.

52007–2024
State v. Selvage green
ohio · 1997
2 sentences

2018State v. Selvage , 80 Ohio St.3d 465 , 468, 687 N.E.2d 433 (1997) ; Pierce , 1st Dist.

1999Additionally, Mantz relies on State v. Selvage (1997), 80 Ohio St.3d 465 , to argue that a speedy trial violation had occurred because he was not arrested at the first reasonable opportunity.

51998–2018
State v. Morgan, 07ca0124-M (10-27-2008) green
ohioctapp · 2008
42009–2023
Moore v. Arizona green
scotus · 1973
41990–2013
Village of Montpelier v. Greeno green
ohio · 1986
31990–2025
State v. Easley, Unpublished Decision (2-22-2005) green
ohioctapp · 2005
32018–2019
State v. Burgess, Unpublished Decision (8-20-2004) green
ohioctapp · 2004
32007–2019
State v. Baker green
ohio · 1997
32001–2018
State v. McBreen green
ohio · 1978
31999–2017
State v. Sinkovitz neutral
ohioctapp · 2014
32016–2016
State v. Thieshen green
ohioctapp · 1977
32013–2014
State v. Steiner green
ohioctapp · 1991
32013–2014
State v. Brown green
ohio · 2002
32005–2012
State v. Brown green
ohio · 2002
32006–2012
State v. Bauer green
ohio · 1980
32007–2011
State v. Stewart, Unpublished Decision (2-23-2006) green
ohioctapp · 2006
32007–2008
State v. Bradley green
ohio · 1989
32006–2008
State v. Moreland green
ohio · 1990
32002–2006
State v. Burks green
ohioctapp · 2018
22022–2024
State v. Mango green
ohioctapp · 2016
22022–2024
State v. McKinney green
ohioctapp · 2011
22022–2023
State v. Clark, Unpublished Decision (3-8-2006) neutral
ohioctapp · 2006
22009–2022
State v. Snyder, Unpublished Decision (6-25-2004) neutral
ohioctapp · 2004
22020–2022
State v. Ladd green
ohio · 1978
22007–2021
State v. Miller, Unpublished Decision (9-26-2006) neutral
ohioctapp · 2006
22016–2021
State v. Davis green
ohioctapp · 2013
22014–2021
State v. Fisher green
ohioctapp · 2012
22013–2021

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2945.71 (302) OH § Ohio Rev. Code § 2945.72 (245) OH § Ohio Rev. Code § 2945.73 (156) OH § Ohio Rev. Code § 2925.11 (39) OH § Ohio Rev. Code § 2903.11 (37) OH § Ohio Rev. Code § 2941.25 (35) OH § Ohio Rev. Code § 2929.14 (33) OH § Ohio Rev. Code § 2941.401 (33) OH § Ohio Rev. Code § 2953.08 (27) OH § Ohio Rev. Code § 2925.03 (26) OH § Ohio Rev. Code § 2923.13 (22) OH § Ohio Rev. Code § 4511.19 (20)

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 640 (1973–2026) OH 496 (1978–2026) FL 395 (1969–2026) NM 272 (1978–2026) IL 210 (1971–2026) WA 190 (1976–2026) GA 155 (1969–2026) MS 148 (1988–2026) PA 137 (1970–2026) NY 133 (1972–2026) MI 118 (1975–2026) MT 116 (1978–2026) AR 115 (1979–2026) CA 114 (1962–2026) TN 103 (1969–2026) AL 64 (1972–2026) WY 62 (1979–2023) DC 62 (1965–2014) IA 59 (1971–2026) NJ 56 (1974–2025) IN 55 (1982–2024) MD 53 (1968–2025) OR 49 (1970–2026) MO 48 (1972–2025) LA 44 (1979–2025) AZ 44 (1976–2026) CO 40 (1975–2026) KS 38 (1978–2026) VA 36 (1987–2025) MN 35 (1978–2025) NC 35 (1981–2026) MA 33 (1973–2025) ID 29 (1963–2025) CT 28 (1981–2023) WI 26 (1990–2026) VT 26 (1984–2024) AK 25 (1971–2025) DE 24 (1979–2026) ND 23 (1993–2025) NH 23 (1981–2022) RI 20 (1979–2015) KY 18 (1995–2026) NV 18 (1967–2026) ME 17 (1972–2026) UT 17 (1968–2026) NE 17 (1989–2025) SC 16 (1986–2026) HI 11 (1980–2025) OK 10 (1970–2023) WV 9 (1979–2010) VI 7 (1990–2026) SD 6 (1988–2026)

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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