State v. Keaton, 2017 Ohio 7036

Keaton was indicted (Mar. 25, 2014) on two counts of nonsupport of dependents covering Mar. 2012–Mar. 2014; an arrest warrant listed a Fornoff Road address.
He was not arrested on that warrant until Feb. 8, 2016 (≈22-month delay) after an unrelated traffic stop.
Keaton entered a not guilty plea, then updated his address to North Harris Avenue while released on bond.
On Aug. 2, 2016 Keaton moved to dismiss for violation of the speedy-trial right under the U.S. and Ohio Constitutions; the trial court denied the motion after a hearing with no witnesses.
Keaton pleaded no contest and was convicted; he appealed arguing the court failed to analyze the Barker v. Wingo factors properly, especially the reason for delay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 22-month delay violated Keaton's Sixth Amendment speedy-trial right	State: delay was not deliberate; defendant did not suffer prejudice and did not assert the right promptly	Keaton: trial court failed to determine/ weigh the reason for the delay under Barker; delay required dismissal	Court: delay triggered Barker inquiry but, balancing factors, no constitutional violation; denial of dismissal affirmed

Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (establishes four-factor speedy-trial balancing test)
Doggett v. United States, 505 U.S. 647 (U.S. 1992) (length of delay is a trigger for Barker analysis; presumption of prejudice approaches one year)
State v. Adams, 144 Ohio St.3d 429 (Ohio 2015) (Ohio adopts Barker framework)
State v. Triplett, 78 Ohio St.3d 566 (Ohio 1997) (delay before a defendant knows of charges weighs negligibly if liberty wasn't infringed)