State v. Belville, 215 N.E.3d 455

David Belville was arrested for felony drug trafficking and was in jail for a portion of the pretrial period (triple-counted under R.C. 2945.71(E)).
On September 16 Belville requested discovery; the state responded the next day with ~1,200 pages and noted it possessed an HD DVR containing months of home-surveillance footage that was still being reviewed.
At a September 18 status conference the parties and court discussed how defense counsel could review the DVR footage; the agreed plan was for the state to copy/transfer the DVR to a second unit so defense counsel could have a usable copy.
The state worked to obtain a second DVR and transfer the footage; it delivered the DVR copy and related investigator notes to defense counsel 43 days after the initial discovery request (October 29).
Belville moved to dismiss on speedy-trial grounds (claiming 283 days elapsed), arguing tolling ended with the state’s next-day initial disclosure; the trial court denied the motion, the Fourth District affirmed, and the Ohio Supreme Court affirmed.

Issue	Belville's Argument	State's Argument	Held
Whether a defendant’s discovery request tolls the statutory 270-day speedy-trial period while the state responds	Tolling ended when the state provided its initial disclosure (next day); later DVR production was "supplemental" and should not extend tolling	A discovery request tolled the speedy-trial clock for the reasonable time needed to respond, which here included time to copy/deliver DVR (43 days)	A defendant’s discovery request tolls the speedy-trial period for the reasonable time the state needs to comply; that period here included the DVR-production delay, so no violation
Whether a trial court must contemporaneously identify tolling events on the record	Trial court cannot make an after-the-fact tolling finding; tolling must be recognized as it occurs	No statutory requirement to identify tolling events contemporaneously; courts commonly rule on tolling when resolving motions	Trial courts need not contemporaneously announce every tolling event; courts may identify tolling events when ruling on speedy-trial motions
Whether failure to provide reciprocal discovery by defendant tolled time	(Argued below) Belville contended the state could not rely on reciprocal-discovery tolling	State argued Belville’s failure to provide reciprocal discovery tolled time	Not decided by the Supreme Court (unnecessary to resolve because resolution of first issue controlled)

State v. Brown, 98 Ohio St.3d 121 (2002) (held a defendant’s discovery request operates as a tolling event under R.C. 2945.72(E))
State v. Sanchez, 110 Ohio St.3d 274 (2006) (R.C. 2945.72(E) tolls a reasonable period for responses to motions and related proceedings)
State v. King, 70 Ohio St.3d 158 (1994) (trial court must journalize sua sponte continuances before speedy-trial period expires)
State v. Ladd, 56 Ohio St.2d 197 (1978) (discussing Speedy Trial Statute purpose of preventing inexcusable delays)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose material favorable evidence upon request)
State v. Palmer, 112 Ohio St.3d 457 (2007) (discussing the purpose and scope of criminal discovery rules)