State v. Kopietz, 2019 Ohio 5277

January 26, 2016: Lucas County indictment charged Kopietz with identity fraud, receiving stolen property, and forgery (offenses from July 23, 2015). Kopietz failed to appear; a capias issued.
While incarcerated in Colorado, Kopietz filed a motion (March 17, 2017) invoking the Interstate Agreement on Detainers (IAD); the trial court denied the motion.
No Ohio detainer was lodged while Kopietz served time in Colorado; he was paroled in Colorado (Aug. 9, 2018) but transferred to Michigan custody because Michigan had a detainer.
Ohio later placed a detainer while Kopietz was in Michigan custody. Separately, on Oct. 11, 2018, a new Lucas County indictment charged different offenses; Kopietz was arrested Oct. 28, 2018.
Kopietz moved to dismiss the Ohio charges under the IAD and Ohio speedy-trial statute; the trial court denied dismissal. He appealed, arguing the state had an implied duty under the IAD to file a detainer and bring him to trial.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Kopietz)	Held
Whether the IAD imposes an implied duty on a state prosecutor to file a detainer or otherwise act with good faith and due diligence to bring a defendant in another state's custody to trial	IAD creates no duty to file a detainer; IAD protections apply only after a detainer exists	Once the prosecutor has actual knowledge of a defendant's location in another state, the prosecutor must act in good faith and due diligence (per Welker) and file a detainer to trigger IAD protections	The court affirmed: no implied duty to file a detainer; IAD applies only when a detainer has been lodged; declining to read additional obligations into the statute

State v. Welker, 141 P.3d 8 (Wash. 2006) (Washington Supreme Court held prosecutor must act in good faith and due diligence to file a detainer once aware of confined defendant)
State v. Anderson, 939 N.E.2d 1317 (Ohio Ct. App. 2010) (IAD does not apply until a detainer exists; court rejects imposing an implied duty on the state)