State v. Forrest, 2021 Ohio 122

Forrest was indicted on multiple sexual-offense counts (rape, attempted rape, importuning, gross sexual imposition, kidnapping) with sexually violent predator specifications; he ultimately pled guilty to amended attempted rape and importuning and received a five-year agreed sentence.
Arrested Sept. 18, 2017; remained in custody until plea on July 23, 2019 (≈ two years).
Multiple delays occurred: defendant requested continuances, moved to disqualify counsel (leading to replacement), filed numerous pro se motions (including raising incompetency), and underwent two psychological evaluations.
Trial court continuances were often recorded “at the defendant’s request”; the competency report found Forrest capable of understanding and choosing between plea and trial.
On appeal Forrest claimed (1) his speedy-trial rights were violated and (2) his trial counsel was ineffective for failing to move to dismiss on speedy-trial grounds, rendering his plea unknowing/ involuntary.
The appellate court applied Barker, found the delay presumptively prejudicial but that most delay resulted from Forrest’s actions, found no demonstrable prejudice, held no constitutional speedy-trial violation, and concluded counsel was not ineffective; conviction and sentence were affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Forrest)	Held
Whether a constitutional speedy-trial violation occurred	Delay did not result from deliberate state action; much delay was defendant-caused; defendant showed no actual prejudice	Nearly two-year pretrial incarceration and passage of time violated speedy-trial right	No violation — delay was presumptively prejudicial but Barker factors (reason for delay, assertion timing, lack of prejudice) weigh against defendant
Whether plea waived speedy-trial claims	Guilty plea generally waives statutory speedy-trial claims; waiver of ineffective assistance claims relating to statutory speedy-trial issues	Claimed plea was not knowing/voluntary because counsel failed to pursue dismissal on speedy-trial grounds (ineffective assistance)	Plea waived statutory speedy-trial challenges; constitutional claim considered on Barker factors and rejected
Whether counsel was ineffective for not moving to dismiss on speedy-trial grounds	A motion to dismiss would have been meritless because no constitutional violation; therefore counsel’s failure was not deficient or prejudicial	Counsel’s omission induced an involuntary plea; undermined voluntariness	Counsel was not ineffective under Strickland because a dismissal motion lacked merit; plea was knowing, intelligent, and voluntary

Kelley v. United States, 57 Ohio St.3d 127 (1991) (guilty plea generally waives statutory speedy-trial claim)
Spates v. State, 64 Ohio St.3d 269 (1992) (limited preservation of ineffective-assistance claims where plea’s voluntariness affected)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance standard)
Bradley v. Washington, 42 Ohio St.3d 136 (1989) (Ohio’s application of Strickland)
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 approaching one year is presumptively prejudicial)
Taylor v. State, 98 Ohio St.3d 27 (2002) (constitutional speedy-trial right under U.S. and Ohio Constitutions)
Thompson v. State, 33 Ohio St.3d 1 (1987) (Ohio does not recognize hybrid representation)
Branch v. State, 9 Ohio App.3d 160 (1983) (discusses constitutional speedy-trial considerations post-plea)