State v. Crawford, 2019 Ohio 3123

In May 2008 a 20‑year‑old woman with developmental disabilities reported she was assaulted in an alley; a SANE exam collected bodily samples and clothing which were sent to BCI for testing.
Initial 2008 forensic work detected blood and a sperm cell on underwear and an amylase (saliva) stain on the victim’s chest, but no identified suspect; the investigation went cold.
In 2016 Marcus Crawford’s DNA was collected in an unrelated rape prosecution; BCI later matched Crawford to the amylase sample from the 2008 kit.
Crawford was indicted in Sept. 2016 for the 2008 rape, tried July 31, 2017, convicted of rape (R.C. 2907.02(A)(2),(B)), and sentenced to 11 years imprisonment, consecutive to a sentence in the 2016 case.
On appeal Crawford argued (1) his statutory and constitutional speedy‑trial rights were violated and (2) the conviction was not supported by sufficient evidence and was against the manifest weight of the evidence.
The Sixth District affirmed, concluding tolling events kept the prosecution within the 270‑day statutory limit and that DNA combined with victim testimony provided legally sufficient and weighty evidence of penetration and identity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crawford’s statutory speedy‑trial right under R.C. 2945.71 was violated	State: trial was within statutory time after accounting for tolled periods	Crawford: 320 days elapsed from indictment to trial, exceeding 270‑day limit	Affirmed for state: 224 days tolled for continuances, motions, counsel changes, discovery; 96 days chargeable < 270 days
Whether Crawford’s constitutional speedy‑trial right was violated	N/A (state argued no violation)	Crawford urged Sixth Amendment violation due to delay	No constitutional violation: delay not presumptively prejudicial and most delay attributable to defendant
Whether evidence was legally sufficient to prove rape (identity and penetration) beyond a reasonable doubt	State: DNA match to chest amylase + victim medical and testimonial evidence established identity and penetration	Crawford: victim didn’t identify him; sperm on underwear inconclusive; alternative innocuous explanations possible	Evidence sufficient: jury could reasonably find penetration and that Crawford was perpetrator based on DNA and victim testimony
Whether conviction was against the manifest weight of the evidence	N/A (state urged verdict be sustained)	Crawford: evidence equally consistent with innocent transfer of DNA; jury should not have believed prosecution	No miscarriage of justice: jury credibility determinations respected; verdict not against manifest weight

State v. Adams, 43 Ohio St.3d 67 (statutory speedy‑trial framework under R.C. 2945.71‑.73)
Barker v. Wingo, 407 U.S. 514 (1972) (four‑factor balancing test for constitutional speedy‑trial claims)
Doggett v. United States, 505 U.S. 647 (1992) (delay becomes presumptively prejudicial as it approaches one year)
State v. Sanchez, 110 Ohio St.3d 274 (2006) (triple‑count jail credit applies only when held solely on the pending charge)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (standards for sufficiency and manifest‑weight review)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency of the evidence)