State v. Carr, 2013 Ohio 5312

Carr pleaded no contest to insurance fraud in a multi-count indictment and the trial court denied motions to dismiss based on speedy-trial rights.
Carr filed numerous pro se motions and the court granted continuances and severances, some sua sponte, affecting the speedy-trial clock.
The insurance-fraud charge (count two) was not pending against Carr until after the April 9, 2010 indictment; the triple-count provision applied from April 10, 2010.
The court eventually found Carr guilty of insurance fraud on November 21, 2011, after a series of continuances and delays.
Carr argues the State violated R.C. 2945.71 et seq. by failing to bring him to trial within the mandated time; the State contends tolling events extended the time.
The appellate court held that tolling events, including Carr’s motions and reasonable continuances, sufficiently extended the speedy-trial period so no violation occurred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Carr's speedy-trial rights were violated for count two.	State contends tolling events extended time.	Carr argues multiple delays violated speedy-trial limits.	No violation; tolling events preserved timely trial.

Singer v. State, 50 Ohio St.2d 103 (Ohio 1977) (mandatory duty to comply with speedy-trial statutes; strict construction against State)
Brecksville v. Cook, 75 Ohio St.3d 53 (Ohio 1996) (speedy-trial time must be strictly enforced; consideration of reasonable delay)
State v. Martin, 56 Ohio St.2d 289 (Ohio 1978) (continuances tolling must be reasonable in purpose and length)
State v. Younker, 2008-Ohio-6889 (Ohio App. 4th Dist. 2008) (timing of tolling when motions are pending; triage of speedy-trial clock)
State v. Dankworth, 172 Ohio App.3d 159 (Ohio App. 2nd Dist. 2007) (separate-trial issues and speedy-trial timing considerations)
State v. Cottrell, 2012-Ohio-4583 (4th Dist. Ross No. 11CA3241 & 11CA3242) (mixed review; tolling and appellate standards for speedy-trial decisions)