State v. Gaston, 2018 Ohio 4575

In July 2013, Matthew Hammond was fatally shot during a nighttime home-invasion; police investigation tied a white Chevy Impala with blood in the rear passenger area to the crime.
Surveillance placed Timothy Gaston and two others at an apartment complex the morning of the murder; vehicle registered to a third party whose car contained Hammond’s blood.
Lake County detectives traveled to Knoxville, TN to locate Gaston; Knoxville Investigator Kingsbury and two U.S. Marshals contacted Gaston at his apartment to determine whether he had to register as a sex offender.
Gaston voluntarily accompanied Kingsbury to the police department, where Kingsbury determined Gaston did not have to register; Ohio detectives then interviewed Gaston after (mistakenly) telling him he had been arrested and giving Miranda warnings.
Gaston admitted being at the scene and implicated two other men; he was indicted on multiple counts, convicted by a jury of aggravated murder and aggravated burglary (with firearm specifications), and sentenced to life with parole eligibility after 47 years.
On appeal Gaston challenged (1) denial of his motion to suppress his statement as the fruit of an unlawful arrest and (2) denial of his motion to dismiss for speedy-trial violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gaston’s statement must be suppressed as the product of an unlawful arrest/illegal custodial interrogation	State: Gaston voluntarily accompanied Tennessee officers; no arrest occurred and statements were not tainted	Gaston: He was effectively arrested by Tennessee officers (for failure to register) at the department at the behest of Ohio officers; interview was custodial and coerced	Court: No unlawful arrest; Kingsbury had no intent to arrest, Gaston was free to leave, and Ohio officers’ mistaken claim of arrest/Miranda warnings did not convert a voluntary interview into an unlawful custodial arrest — suppression denied
Whether Gaston’s right to a speedy trial was violated, requiring discharge	State: Gaston executed an unlimited, knowing, written waiver of speedy-trial rights; he did not timely demand trial after withdrawing waiver; any post-withdrawal delay (61 days) was reasonable	Gaston: Waiver should not preclude relief for delays (including alleged 26-month delay on motion rulings); trial scheduling and delays violated statutory/constitutional speedy-trial rights	Court: Waiver was valid, unlimited, and voluntary; Gaston did not assert the right earlier; the 61-day interval after withdrawal was reasonable under Barker balancing — dismissal denied

State v. Burnside, 100 Ohio St.3d 152 (mixed questions of law and fact in suppression review)
State v. Mills, 62 Ohio St.3d 357 (trial court as factfinder on suppression hearings)
State v. Mayl, 106 Ohio St.3d 207 (appellate review standard for suppression findings)
State v. Barker, 53 Ohio St.2d 135 (elements of arrest under Ohio law)
Barker v. Wingo, 407 U.S. 514 (balancing test for speedy-trial claims)
State v. O’Brien, 34 Ohio St.3d 7 (effect of written waiver of speedy-trial rights)
State v. Pachay, 64 Ohio St.2d 218 (statutory speedy-trial provisions strictly enforced)