State v. Jackson, 2016 Ohio 5196

In June–July 2011, municipal-court warrants issued charging Mary Jackson with writing bad checks and failing to return a rented chainsaw.
Police searched the Bellevue, Kentucky address listed on documents for about a month; efforts then were turned over to the warrants unit.
No further active efforts to locate Jackson are documented; the state did not discover that Jackson was incarcerated in Ohio for 18 months (May 2012–Oct 2013).
Jackson was arrested on the outstanding warrants on June 29, 2015 — nearly four years after issuance — and moved to dismiss based on speedy-trial protections and statute of limitations.
Trial court held the statute of limitations was not a bar but found a Sixth Amendment speedy-trial violation due to the state’s lack of reasonable diligence and dismissed the charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the four-year delay between issuance of warrants and arrest violated Jackson’s Sixth Amendment speedy-trial rights	State: it exercised reasonable diligence (initial search + turning case to warrants unit); delay should not bar prosecution	Jackson: delay was presumptively prejudicial; state failed to use reasonable diligence so speedy-trial claim is meritorious	Court affirmed dismissal: four-year delay + lack of reasonable diligence by state presumed prejudice and violated speedy-trial rights

Barker v. Wingo, 407 U.S. 514 (establishes four-factor speedy-trial balancing test)
Doggett v. United States, 505 U.S. 647 (long, negligent delay can create presumed prejudice to the defense)
Redd v. Sowders, 809 F.2d 1266 (prosecutor’s burden to explain pretrial delay; diligence requirement)
State v. Sears, 166 Ohio App.3d 166 (delay threshold for further inquiry; prejudice analysis)
State v. Triplett, 78 Ohio St.3d 566 (contrast: long delay not prejudicial where defendant knew of charges and impeded service)