Ohio Rev. Code » Chapter 2945
Ohio Revised Code

Ohio Rev. Code § 2945.72 (2026)

Extending time for hearing or trial

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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. 7th Dist. 2001).
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State v. High, 757 N.E.2d 1176 (Ohio Ct. App. 7th Dist. 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, 887 N.E.2d 319 (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, 853 N.E.2d 283 (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, 245 N.E.3d 500. · 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, 215 N.E.3d 455. · 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, 971 N.E.2d 937. · 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, 75 Ohio St. 3d 53 (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. · 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. · cites it 9× “Speedy-trial time is tolled by certain events delineated in R.C. 2945.72.”
State v. Brown, 2002-Ohio-7040, 98 Ohio St. 3d 121. · 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. 8th Dist. 1992).
State v. Geraldo, 468 N.E.2d 328 (Ohio Ct. App. 6th Dist. 1983).
City of Akron v. Downey, 495 N.E.2d 28 (Ohio Ct. App. 9th Dist. 1984).
State v. Perry, 588 N.E.2d 897 (Ohio Ct. App. 3d Dist. 1990).
Ohio Rev. Code § 2945.72(A): 94 cases
State v. Bailey, 750 N.E.2d 603 (Ohio Ct. App. 2d Dist. 2000).
State v. Woodard, 2022-Ohio-3081.
State v. Wagner, 2021-Ohio-1671.
State v. Haney, 2013-Ohio-2823.
State v. Roulette, 840 N.E.2d 645 (Ohio Ct. App. 4th Dist. 2005).
Ohio Rev. Code § 2945.72(A)(2): 5 cases
State v. Woullard, 814 N.E.2d 964 (Ohio Ct. App. 2d Dist. 2004).
State v. Sanders, 2016-Ohio-7204.
State v. Mays, 2024-Ohio-4616, 251 N.E.3d 41.
State v. Russell, 2022-Ohio-1746.
State v. Mercer, 2025-Ohio-1158.
Ohio Rev. Code § 2945.72(B): 61 cases
State v. Palmer, 84 Ohio St. 3d 103 (1998).
State v. Cimpaye, 2020-Ohio-2740, 154 N.E.3d 415.
State v. Palmer, 84 Ohio St. 3d 103 (1998).
State v. Cook, 2016-Ohio-2823.
State v. Sheline, 2019-Ohio-528.
Ohio Rev. Code § 2945.72(C): 53 cases
State v. Carr, 2013-Ohio-5312.
State v. Crawford, 2019-Ohio-2660.
State v. Stoddard, 2020-Ohio-893, 152 N.E.3d 990.
State v. Rockwell, 608 N.E.2d 1118 (Ohio Ct. App. 10th Dist. 1992).
State v. Wood, 2024-Ohio-5597.
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. “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, 215 N.E.3d 455. “71(E), Belville was entitled to credit for 283 days awaiting trial without counting tolling events.”
State v. Peabody, 2024-Ohio-185.
State v. Wells, 2021-Ohio-2585. “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, 215 N.E.3d 455. “71(E), Belville was entitled to credit for 283 days awaiting trial without counting tolling events.”
State v. Brown, 2002-Ohio-7040, 98 Ohio St. 3d 121. “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. 7th Dist. 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, 853 N.E.2d 283 (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, 75 Ohio St. 3d 53 (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. 10th Dist. 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. 8th Dist. 1996).
State v. Woodard, 2022-Ohio-3081.
State v. Lewis, 2021-Ohio-1895.
State v. Carr, 2013-Ohio-5312.
State v. Campbell, 779 N.E.2d 811 (Ohio Ct. App. 1st Dist. 2002).
Ohio Rev. Code § 2945.72(H): 366 cases
State v. Ramey, 2012-Ohio-2904, 971 N.E.2d 937. “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. 7th Dist. 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, 245 N.E.3d 500. “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, 129 N.E.3d 437.
State v. Peabody, 2024-Ohio-185.
Ohio Rev. Code § 2945.72(I): 4 cases
State v. Hollaender, 2014-Ohio-1782.
State v. Ojezua, 2018-Ohio-3812.
Cleveland v. Gross, 2022-Ohio-193.
State v. Counts, 2024-Ohio-1362.
Ohio Rev. Code § 2945.72(J): 2 cases
State v. Vanmeter, 2024-Ohio-1458.
State v. Boyd, 2024-Ohio-1517.
Ohio Rev. Code § 2945.72(c): 1 case
State v. Fuller, 2012-Ohio-1979.
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