State v. Glanton, 2020 Ohio 834

In Nov. 2012 Glanton was stopped for speeding; officers found $8,997 in cash and evidence of multiple cell phones/receipts suggesting purchases in others’ names. He was indicted on possessing criminal tools and money laundering with a forfeiture specification.
Glanton posted bond, failed to appear in June 2013 because he was serving an unrelated 8-year sentence for cocaine trafficking in Scioto County; the Wood County case was placed on the inactive docket.
In Oct. 2017 Glanton filed a pro se R.C. 2941.401 motion to dismiss for lack of a speedy trial; the court denied it for procedural deficiency but appointed new counsel.
On Jan. 29, 2018 (plea/sentencing entry reflected Feb. 1, 2018), Glanton pleaded guilty pursuant to a plea agreement: he consented to forfeiture of the $8,997 and received concurrent 12‑month sentences to run concurrently with his existing sentence.
Glanton appealed, arguing (1) R.C. 2981.02 is unconstitutional under the Eighth Amendment (Excessive Fines) and the forfeiture was disproportionate as applied, and (2) the trial court erred in denying his speedy‑trial motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment challenge to R.C. 2981.02 forfeiture	Glanton: statute allows seizure of all proceeds without proportionality and is an excessive fine; as‑applied court made no proportionality analysis	State: forfeiture here was part of a plea agreement (not effected by Chapter 2981), so Glanton lacks standing to challenge the statute	Court: Forfeiture was effectuated by Glanton’s plea agreement; he lacks standing to challenge R.C. 2981.02 or proportionality under that statute; claim denied
Denial of motion to dismiss under speedy‑trial statutes and constitutional speedy‑trial claim	Glanton: nearly 62‑month delay deprived him of statutory (R.C. 2941.401) and constitutional speedy‑trial rights	State: guilty plea waived speedy‑trial claims; alternatively delay attributable to Glanton because he failed to invoke statutory procedure and he did not diligently assert his right	Court: Guilty plea (entered knowingly under Crim.R. 11) waived statutory and constitutional speedy‑trial claims; alternatively, Glanton never triggered R.C. 2941.401 and Barker/Doggett balancing favors the State; claim denied

Timbs v. Indiana, 139 S.Ct. 682 (Eighth Amendment Excessive Fines Clause applies to the states)
Doggett v. United States, 505 U.S. 647 (prolonged delay is presumptively prejudicial and triggers Barker balancing)
Barker v. Wingo, 407 U.S. 514 (four‑factor balancing test for constitutional speedy‑trial claims)
State v. Bloomer, 122 Ohio St.3d 200 (standing required to challenge constitutionality of an ordinance/statute)
State v. Ketterer, 111 Ohio St.3d 70 (guilty plea waives collateral constitutional claims that occurred before plea)
State v. Kelley, 57 Ohio St.3d 127 (guilty plea waives statutory speedy‑trial claims)
State v. Adams, 43 Ohio St.3d 67 (Ohio statutory speedy‑trial provisions implement constitutional right)
State v. Whitmore, 162 Ohio App.3d 659 (forfeiture may be governed by plea agreement where defendant expressly acknowledges forfeiture in plea)