State v. Jones, 2011 Ohio 3404

Jones pled guilty to failure to register and was placed in community control; he absconded to Kentucky, triggering multiple warrants.
Warrants issued for probation violation and for failure to provide a change of address; Jones remained in Kentucky while extradition was pursued.
Governor's Warrant issued in 2010; Jones was extradited back to Ohio and brought to court in March 2010.
Jones sought dismissal on speedy-trial grounds, arguing the 90-day clock expired; the State argued IAD or tolling applied.
Trial court dismissed charges with prejudice; the State moved to vacate and argued tolling and 120-day IAD period.
Appellate court held the State waived its argument by not raising 270-day clock below and affirmed dismissal

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the triple-count provision applies or is waived	Jones presented prima facie case for triple-count; State failed to argue 270-day clock below	State could rebut with 270-day clock if properly raised; 270-day argument waived	Waived; trial court affirmed

State v. Sanchez, 110 Ohio St.3d 274 (2006) (speedy-trial calculation framework; 2945.71)
State v. Brown, 131 Ohio App.3d 387 (1998) (mixed question of law and fact; deference to fact findings)
State v. Butcher, 27 Ohio St.3d 28 (1986) (triple-count invocation and burden on State)
State v. Parker, 113 Ohio St.3d 207 (2007) (charges arising from same conduct; triple-count applicability when in custody)
Brecksville v. Cook, 75 Ohio St.3d 53 (1996) (strict construction of speedy-trial statutes against State)