Ohio Rev. Code » Chapter 2945
Ohio Revised Code

Ohio Rev. Code § 2945.72 (2026)

Extending time for hearing or trial

✓ current as of May 2026
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Effective:
April 6, 2023
Latest Legislation:
House Bill 343 - 134th General Assembly
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The time within which an accused must be brought to trial, or, in the case of felony, to preliminary hearing and trial, may be extended only by the following:

(A) Any period during which the accused is unavailable for hearing or trial, by reason of other criminal proceedings against the accused, within or outside the state, by reason of confinement in another state, or by reason of the pendency of extradition proceedings, provided that the prosecution exercises reasonable diligence to secure availability of the accused;

(B) Any period during which the accused is mentally incompetent to stand trial or during which the accused's mental competence to stand trial is being determined, or any period during which the accused is physically incapable of standing trial;

(C) Any period of delay necessitated by the accused's lack of counsel, provided that such delay is not occasioned by any lack of diligence in providing counsel to an indigent accused upon the accused's request as required by law;

(D) Any period of delay occasioned by the neglect or improper act of the accused;

(E) Any period of delay necessitated by reason of a plea in bar or abatement, motion, proceeding, or action made or instituted by the accused;

(F) Any period of delay necessitated by a removal or change of venue pursuant to law;

(G) Any period during which trial is stayed pursuant to an express statutory requirement, or pursuant to an order of another court competent to issue such order;

(H) The period of any continuance granted on the accused's own motion, and the period of any reasonable continuance granted other than upon the accused's own motion;

(I) Any period during which an appeal filed pursuant to section 2945.67 of the Revised Code is pending;

(J) Any period during which an appeal or petition for a writ filed pursuant to section 2930.19 of the Revised Code is pending.

Last updated March 9, 2023 at 4:01 PM

Notes of Decisions
Cited in 793 cases (239 in the last 5 years), 1956–2026 · leading case: State v. High, 757 N.E.2d 1176 (Ohio Ct. App. 2001).
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State v. High, 757 N.E.2d 1176 (Ohio Ct. App. 2001). · cites it 28× “However, as appellee notes, R.C. 2945.72 provides: “The time within which an accused must be brought to trial * * * may be extended only by the following: * * “(E) Any period of delay necessitated by reason of a plea in bar or abatement, motion, proceeding, or action made or…”
State v. Blackburn, 118 Ohio St. 3d 163 (Ohio 2008). · cites it 19× “{¶ 9} On appeal, the state argued that Adams applied to a waiver of speedy-trial rights and that this case involves tolling of the time for a speedy trial under R.C. 2945.72. The Ashtabula County Court of Appeals rejected that argument, holding that “R.”
State v. Sanchez, 110 Ohio St. 3d 274 (Ohio 2006). · cites it 15× “{¶ 8} The running of the speedy-trial clock may be temporarily stopped, that is, tolled, only for reasons listed in R.C. 2945.72. 3 Upon review of a speedy-trial issue, a court is required to count the days of delay chargeable to either side and determine whether the case was…”
State v. Knott, 2024 Ohio 2289 (Ohio Ct. App. 2024). · cites it 27× “Speedy-trial time may be extended/tolled for a number of circumstances listed under R.C. 2945.72(A) through (J). {¶ 21} Pursuant to R.”
State v. Belville, 2022 Ohio 3879 (Ohio 2022). · cites it 18× “71(E), Belville was entitled to credit for 283 days awaiting trial without counting tolling events.”
State v. Ramey, 2012 Ohio 2904 (Ohio 2012). · cites it 14× “Accordingly, R.C. 2945.72 contains an exhaustive list of events and circumstances that extend the time within which a defendant must be brought to trial.”
City of Brecksville v. Cook, 661 N.E.2d 706 (Ohio 1996). · cites it 13× “71 are not absolute in all circumstances, but a certain measure of flexibility was intended by the General Assembly by the enactment of R.C. 2945.72, wherein discretionary authority is *56 granted to extend the trial date beyond the R.”
Brecksville v. Cook, 1996 Ohio 171 (Ohio 1996). · cites it 15× “” 3 SUPREME COURT OF OHIO certain measure of flexibility was intended by the General Assembly by the enactment of R.C. 2945.72, wherein discretionary authority is granted to extend the trial date beyond the R.”
State v. Palmer, 860 N.E.2d 1011 (Ohio 2007). · cites it 11× “{¶ 12} R.C. 2945.72 states circumstances that justify an extension of statutory speedy-trial time.”
State v. Sanders, 2019 Ohio 1524 (Ohio Ct. App. 2019). · cites it 15× “Speedy trial time may, however, be tolled by certain events delineated in R.C. 2945.72, including where the defendant’s improper actions or neglect causes delay or for “the period of any reasonable continuance granted other than upon the accused’s own motion.”
State v. Wells, 2021 Ohio 2585 (Ohio Ct. App. 2021). · cites it 9× “Speedy-trial time is tolled by certain events delineated in R.C. 2945.72.”
State v. Brown, 2002 Ohio 7040 (Ohio 2002). · cites it 8× “R.C. 2945.72 states: {¶15} “The time within which an accused must be brought to trial, or, in the case of felony, to preliminary hearing and trial, may be extended only by the following: {¶16} “* * * {¶17} “(E) Any period of delay necessitated by reason of a plea in bar or…”
Show all 793 citing cases →
— Ohio Rev. Code § 2945.72(1) — 4 cases
State v. Spinks, 607 N.E.2d 1130 (Ohio Ct. App. 1992).
State v. Geraldo, 468 N.E.2d 328 (Ohio Ct. App. 1983).
City of Akron v. Downey, 495 N.E.2d 28 (Ohio Ct. App. 1984).
State v. Perry, 588 N.E.2d 897 (Ohio Ct. App. 1990).
— Ohio Rev. Code § 2945.72(A) — 94 cases
State v. Bailey, 750 N.E.2d 603 (Ohio Ct. App. 2000).
State v. Woodard, 2022 Ohio 3081 (Ohio Ct. App. 2022).
State v. Wagner, 2021 Ohio 1671 (Ohio Ct. App. 2021).
State v. Haney, 2013 Ohio 2823 (Ohio Ct. App. 2013).
State v. Roulette, 840 N.E.2d 645 (Ohio Ct. App. 2005).
— Ohio Rev. Code § 2945.72(A)(2) — 5 cases
State v. Woullard, 814 N.E.2d 964 (Ohio Ct. App. 2004).
State v. Sanders, 2016 Ohio 7204 (Ohio Ct. App. 2016).
State v. Mays, 2024 Ohio 4616 (Ohio 2024).
State v. Russell, 2022 Ohio 1746 (Ohio Ct. App. 2022).
State v. Mercer, 2025 Ohio 1158 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2945.72(B) — 61 cases
State v. Palmer, 84 Ohio St. 3d 103 (Ohio 1998).
State v. Cimpaye, 2020 Ohio 2740 (Ohio Ct. App. 2020).
State v. Palmer, 1998 Ohio 507 (Ohio 1998).
State v. Cook, 2016 Ohio 2823 (Ohio Ct. App. 2016).
State v. Sheline, 2019 Ohio 528 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2945.72(C) — 53 cases
State v. Carr, 2013 Ohio 5312 (Ohio Ct. App. 2013).
State v. Crawford, 2019 Ohio 2660 (Ohio Ct. App. 2019).
State v. Stoddard, 2020 Ohio 893 (Ohio Ct. App. 2020).
State v. Rockwell, 608 N.E.2d 1118 (Ohio Ct. App. 1992).
State v. Wood, 2024 Ohio 5597 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2945.72(D) — 103 cases
State v. Palmer, 860 N.E.2d 1011 (Ohio 2007). “{¶ 12} R.C. 2945.72 states circumstances that justify an extension of statutory speedy-trial time.”
State v. Sanders, 2019 Ohio 1524 (Ohio Ct. App. 2019). “Speedy trial time may, however, be tolled by certain events delineated in R.C. 2945.72, including where the defendant’s improper actions or neglect causes delay or for “the period of any reasonable continuance granted other than upon the accused’s own motion.”
State v. Belville, 2022 Ohio 3879 (Ohio 2022). “71(E), Belville was entitled to credit for 283 days awaiting trial without counting tolling events.”
State v. Peabody, 2024 Ohio 185 (Ohio Ct. App. 2024).
State v. Wells, 2021 Ohio 2585 (Ohio Ct. App. 2021). “Speedy-trial time is tolled by certain events delineated in R.C. 2945.72.”
— Ohio Rev. Code § 2945.72(E) — 338 cases
State v. Belville, 2022 Ohio 3879 (Ohio 2022). “71(E), Belville was entitled to credit for 283 days awaiting trial without counting tolling events.”
State v. Brown, 2002 Ohio 7040 (Ohio 2002). “R.C. 2945.72 states: {¶15} “The time within which an accused must be brought to trial, or, in the case of felony, to preliminary hearing and trial, may be extended only by the following: {¶16} “* * * {¶17} “(E) Any period of delay necessitated by reason of a plea in bar or…”
State v. High, 757 N.E.2d 1176 (Ohio Ct. App. 2001). “However, as appellee notes, R.C. 2945.72 provides: “The time within which an accused must be brought to trial * * * may be extended only by the following: * * “(E) Any period of delay necessitated by reason of a plea in bar or abatement, motion, proceeding, or action made or…”
State v. Sanchez, 110 Ohio St. 3d 274 (Ohio 2006). “{¶ 8} The running of the speedy-trial clock may be temporarily stopped, that is, tolled, only for reasons listed in R.C. 2945.72. 3 Upon review of a speedy-trial issue, a court is required to count the days of delay chargeable to either side and determine whether the case was…”
State v. Homan, 732 N.E.2d 952 (Ohio 2000).
— Ohio Rev. Code § 2945.72(F) — 13 cases
City of Brecksville v. Cook, 661 N.E.2d 706 (Ohio 1996). “71 are not absolute in all circumstances, but a certain measure of flexibility was intended by the General Assembly by the enactment of R.C. 2945.72, wherein discretionary authority is *56 granted to extend the trial date beyond the R.”
Brecksville v. Cook, 1996 Ohio 171 (Ohio 1996). “” 3 SUPREME COURT OF OHIO certain measure of flexibility was intended by the General Assembly by the enactment of R.C. 2945.72, wherein discretionary authority is granted to extend the trial date beyond the R.”
City of Gahanna v. Partlow, 501 N.E.2d 51 (Ohio Ct. App. 1985).
Rose v. Vill. of Peninsula, 839 F. Supp. 517 (N.D. Ohio 1993).
Rose v. Vill. of Peninsula, 875 F. Supp. 442 (N.D. Ohio 1995).
— Ohio Rev. Code § 2945.72(G) — 7 cases
State v. Mays, 671 N.E.2d 553 (Ohio Ct. App. 1996).
State v. Woodard, 2022 Ohio 3081 (Ohio Ct. App. 2022).
State v. Lewis, 2021 Ohio 1895 (Ohio Ct. App. 2021).
State v. Carr, 2013 Ohio 5312 (Ohio Ct. App. 2013).
State v. Campbell, 779 N.E.2d 811 (Ohio Ct. App. 2002).
— Ohio Rev. Code § 2945.72(H) — 366 cases
State v. Ramey, 2012 Ohio 2904 (Ohio 2012). “Accordingly, R.C. 2945.72 contains an exhaustive list of events and circumstances that extend the time within which a defendant must be brought to trial.”
State v. High, 757 N.E.2d 1176 (Ohio Ct. App. 2001). “However, as appellee notes, R.C. 2945.72 provides: “The time within which an accused must be brought to trial * * * may be extended only by the following: * * “(E) Any period of delay necessitated by reason of a plea in bar or abatement, motion, proceeding, or action made or…”
State v. Knott, 2024 Ohio 2289 (Ohio Ct. App. 2024). “Speedy-trial time may be extended/tolled for a number of circumstances listed under R.C. 2945.72(A) through (J). {¶ 21} Pursuant to R.”
State v. Martin (Slip Opinion), 2019 Ohio 2010 (Ohio 2019).
State v. Peabody, 2024 Ohio 185 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2945.72(I) — 4 cases
State v. Hollaender, 2014 Ohio 1782 (Ohio Ct. App. 2014).
State v. Ojezua, 2018 Ohio 3812 (Ohio Ct. App. 2018).
Cleveland v. Gross, 2022 Ohio 193 (Ohio Ct. App. 2022).
State v. Counts, 2024 Ohio 1362 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2945.72(J) — 2 cases
State v. Vanmeter, 2024 Ohio 1458 (Ohio Ct. App. 2024).
State v. Boyd, 2024 Ohio 1517 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2945.72(c) — 1 case
State v. Fuller, 2012 Ohio 1979 (Ohio Ct. App. 2012).
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