State v. Fields, 2013 Ohio 4970

In March 2007 Richard A. Fields was charged with DUI (R.C. 4511.19(A)(1)(a)), BAC over limit (R.C. 4511.19(A)(1)(h)), and failure to yield; he pleaded not guilty.
At a May 9, 2007 hearing Fields asked for a continuance to retain a public defender and expressly waived his speedy-trial rights on the record.
Fields failed to appear at the next trial date and a warrant issued; the case remained unresolved for years.
Fields filed a motion to dismiss for violation of R.C. 2945.71 speedy-trial rules on June 3, 2011; the trial court denied the motion and the case proceeded.
After a June 27, 2012 continuance for pretrial/discovery, Fields was tried and convicted at a bench trial on August 6, 2012; he appealed claiming speedy-trial violation.

Issue	Fields' Argument	State's Argument	Held
Whether denial of Fields' motion to dismiss violated his statutory and constitutional speedy-trial rights	The delay (about five years from 2007 failure to appear; ~398 days from his 2011 motion) violated speedy-trial rules; he was "available" while jailed on another matter and thus time was not tolled	Fields waived speedy-trial rights in open court in 2007; waiver was effective until he reasserted rights in 2011, and the post-reassertion delay was reasonable given filings and continuances; no prejudice shown	Court affirmed: Fields waived his rights in 2007; after his 2011 motion, the 398‑day delay was reasonable under Barker factors and did not violate constitutional speedy-trial guarantees

Brecksville v. Cook, 75 Ohio St.3d 53 (Ohio 1996) (speedy-trial statutes must be strictly construed against the State)
Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four-factor balancing test for constitutional speedy-trial claims)
State v. O'Brien, 34 Ohio St.3d 7 (Ohio 1987) (defendant may revoke unlimited waiver by reasserting speedy-trial right; timing rules follow)
State v. King, 70 Ohio St.3d 158 (Ohio 1994) (waiver of speedy trial must be in writing or made on the record to be effective)