State v. Horsley, 2011 Ohio 1355

Defendant Horsley rammed a hotel exterior wall on July 11, 2009; he was arrested for DUI and a protection-order violation and jailed until July 20, 2009.
Officer Gannon’s incident report listed vandalism and valued damage at $5,000 in August 2009.
November 6, 2009 grand jury indicted Horsley for vandalism (fourth-degree felony); arrest on the indictment occurred November 9, 2009.
Motion to dismiss argued the speedy-trial period expired before trial; stipulations acknowledged that damage value was unknown at arrest but known by August 12, 2009.
Trial court held that the speedy-trial period began on November 6, 2009 due to the lack of known value at the July 11 arrest.
The appellate court reversed, holding the state knew or should have known the facts constituting vandalism at the July 11, 2009 arrest and the indictment was timely under applicable speedy-trial rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the speedy-trial clock begin for an additional indictment arising from the same incident?	Horsley	Governing facts existed at arrest	Clock began at arrest; indictment timely

State v. Clay, 9 Ohio App.3d 216 (Ohio App.3d 1983) (timing begins from initial arrest when facts exist for original and new charges)
State v. Adams, 43 Ohio St.3d 67 (Ohio 1989) (new charges arising from same facts follow original period if facts known at initial indictment)
State v. Baker, 78 Ohio St.3d 108 (Ohio 1997) (new charges based on facts not known initially get a new 270-day period)
State v. Parker, 113 Ohio St.3d 207 (Ohio 2007) (multiple charges with common history; triple count due to pretrial incarceration on multiple charges)
State v. Singer, 50 Ohio St.2d 103 (Ohio 1977) (mandatory duty to comply with speedy-trial statutes)