State v. Castro, 2014 Ohio 2398

Castro appeals denial of motion to dismiss indictment after the trial court vacated his guilty plea to two counts of sexual battery.
Castro previously pled guilty to two sexual-battery counts on an 14-count indictment; the state moved to vacate the plea due to alleged witness-bribery conspiracy.
The bribery conspiracy involved Castro and his attorney, tainting plea proceedings prior to sentencing.
The trial court vacated the plea and reinstated the indictment; Castro later pled no contest to two counts.
Castro challenges the indictment reinstatement as double jeopardy and also raises speedy-trial arguments.
The court affirms, ruling manifest necessity supported vacating the plea and rejecting the speedy-trial claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did vacating the plea and reinstating the indictment violate double jeopardy?	Castro argues jeopardy attached; vacating violated the Fifth Amendment.	State asserts manifest necessity to taint plea due to conspiracy.	No; manifest necessity justified vacating and reinstitution.
Were Castro’s speedy-trial rights violated by the delay after vacating the plea?	Castro claims over 300 speedy-trial days; denial of speedy-trial rights.	Delay arising from plea vacatur and conduct did not violate rights.	No; rights not violated, and counsel not ineffective.

Somerville, 410 U.S. 458 (U.S. Supreme Court 1973) (manifest necessity; ends of public justice justify mistrial/recourse to reinstitution)
Wade v. Hunter, 336 U.S. 684 (U.S. Supreme Court 1949) (jeopardy considerations and ends of public justice)
North Carolina v. Pearce, 395 U.S. 711 (U.S. Supreme Court 1969) (double jeopardy protections; sentencing considerations)
Patterson, 406 F.3d 1095 (9th Cir. 2005) (jeopardy start; constitutional considerations)
Barker v. Wingo, 407 U.S. 514 (U.S. Supreme Court 1972) (speedy-trial framework factors)
Doggett v. United States, 505 U.S. 647 (U.S. Supreme Court 1992) (presumptive prejudice when delay extends)