State v. Logan, 2014 Ohio 816

Jeremy Logan was charged in a multi-count indictment after a 2012 homicide; charges included aggravated murder, felony murder, felonious assault counts, and firearm specifications. He was arrested Feb 24, 2012.
Defense counsel filed discovery/bill of particulars in March 2012; pretrials and continuances followed for "ongoing discovery."
Logan executed a written speedy-trial waiver in open court on April 16, 2012 (to Sept. 30, 2012) and a second written waiver on Sept. 17, 2012 (to Dec. 31, 2012).
Logan filed pro se motions (July–Sept. 2012) seeking disqualification of counsel, additional psychiatric evaluation, and discovery; he also had a bipolar disorder diagnosis and complained medication was withheld in jail.
Codefendant Robinson went to trial in Oct. 2012; Logan testified for the state. On Oct. 26, 2012 Logan pled guilty to an amended involuntary manslaughter count with a five-year firearm specification; remaining counts were dismissed. He was sentenced to 10 years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of speedy-trial waivers	Waivers were valid; discovery/motions tolled speedy time and defendant waived speedy-trial rights by plea	Waivers were not knowingly, intelligently, voluntarily made because Logan was unmedicated and had pending pro se motion to disqualify counsel	Waivers valid; discovery motions and waivers tolled time; even if brief resumption occurred, total days before plea were <270 days; plea waived statutory speedy-trial claim
Ineffective assistance for consenting to continuances/waivers	State: counsel’s waivers/continuances were reasonable trial strategy/preparation and the claim is waived by guilty plea	Logan: counsel ineffective for not forcing a trial within statutory limits	Claim rejected: guilty plea waives statutory speedy-trial ineffective-assistance claim; waivers presumed sound trial strategy for preparation
Trial court’s investigation of pro se motion to disqualify counsel	Court: minimal inquiry sufficed given record; defendant later affirmed satisfaction with counsel and accepted plea	Logan: court failed to adequately inquire into his pro se disqualification motion	No reversible error: record shows defendant continued working with counsel, expressed satisfaction at plea and during codefendant trial; minimal inquiry requirement met

State v. Kelley, 57 Ohio St.3d 127 (Ohio 1991) (guilty plea waives statutory speedy-trial right)
Montpelier v. Greeno, 25 Ohio St.3d 170 (Ohio 1986) (same principle regarding waiver by plea)
State v. Brown, 98 Ohio St.3d 121 (Ohio 2002) (demand for discovery or bill of particulars tolls speedy-trial time)
State v. King, 70 Ohio St.3d 158 (Ohio 1994) (counsel may waive speedy-trial right as part of trial preparation)
State v. McBreen, 54 Ohio St.2d 315 (Ohio 1978) (continuances/waivers can be trial strategy)
State v. Taylor, 98 Ohio St.3d 27 (Ohio 2002) (waiver for preparation can be made without defendant’s express consent)
State v. Ketterer, 111 Ohio St.3d 70 (Ohio 2006) (trial court duty to inquire into indigent defendant’s motion to disqualify counsel)