State v. Hornsby, 2020 Ohio 1526

Apr. 25, 2017: Montgomery County grand jury indicted Gregory Hornsby for aggravated possession of fentanyl (5th-degree felony).
Service attempts failed; Hornsby missed arraignments and a warrant was issued May 23, 2017 listing a Connersville, Indiana address.
Dec. 14, 2018: Hornsby, incarcerated at Branchville Correctional Facility (IN), filed a petition claiming a detainer was lodged May 23, 2017 and asking for final disposition or dismissal under detainer procedures.
Trial court ordered the State to respond by Jan. 28, 2019; the State did not respond, and the court dismissed the indictment Feb. 15, 2019 under R.C. 2963.30 (Ohio’s Interstate Agreement on Detainers implementation).
Hornsby filed an interstate notice of imprisonment Feb. 26, 2019. The State appealed; the appellate court reversed Feb. 17, 2020, holding no detainer had been lodged and the IAD provisions did not apply, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly dismissed the indictment under R.C. 2963.30 (Interstate Agreement on Detainers)	Dismissal was erroneous because the State never lodged a detainer; R.C. 2963.30 procedures are triggered only by a detainer	Hornsby asserted a detainer had been lodged (May 23, 2017) and sought disposition or dismissal under detainer procedures; alternatively relied on Crim.R.47/48 or speedy-trial rules	Reversed: no detainer was placed, so R.C. 2963.30 did not apply; trial court erred in dismissing; case remanded.

Carchman v. Nash, 473 U.S. 716 (definition and legislative history of "detainer" under the Interstate Agreement on Detainers)
State v. Sanchez, 853 N.E.2d 283 (Ohio Supreme Court discussion of detainer concepts citing Carchman)