State v. Long (Slip Opinion), 168 N.E.3d 1163

In 2015 Long pleaded guilty, was convicted (aggregate 11-year sentence), and appealed; on March 7, 2016 the Second District reversed and remanded because the plea colloquy was deficient.
Long remained imprisoned until June 21, 2016, was brought to county jail; the state offered the same plea it had before; the court set pretrials and a trial date.
Sept. 21, 2016 Long filed a first motion to dismiss for violation of his speedy-trial right; the trial court heard argument and denied that motion Oct. 26, 2016.
The docket then shows little activity for about nine months; on Aug. 7, 2017 Long filed a second motion to dismiss citing the full post-remand delay; the trial court denied it, and on Sept. 21, 2017 Long pleaded no contest to reduced charges and received a 5-year sentence.
The Second District affirmed, concluding no speedy-trial violation; the Ohio Supreme Court accepted discretionary review on whether the speedy-trial clock runs from the date of appellate remand and whether a motion to dismiss resets the clock.
The Ohio Supreme Court held the speedy-trial clock begins on the date of the appellate remand, a motion to dismiss does not reset the clock, and that the post-remand delay here violated Long’s constitutional speedy-trial rights; it reversed the court of appeals and vacated the conviction.

Issue	Plaintiff's Argument (Long)	Defendant's Argument (State / opposing)	Held
When does the speedy-trial clock begin after an appellate reversal?	Clock begins on date the court of appeals remands the case.	(State conceded remand date was proper start; court of appeals used a later date.)	Clock begins on the date of the appellate remand.
Does filing a motion to dismiss for speedy-trial violations reset the speedy-trial clock?	No — allowing a motion to reset the clock would penalize a defendant for asserting the right.	Court of appeals treated the post-motion date as restarting the clock.	A motion to dismiss does not reset the speedy-trial clock.
Did the post-remand delay violate the Sixth Amendment / Ohio speedy-trial right under Barker v. Wingo?	Delay exceeded one year, Barker’s four factors (length, reason, assertion, prejudice) all favor Long — conviction must be vacated.	Delay was not sufficiently prejudicial; reasons included some neutral court scheduling and some defendant-caused delay; Long showed no particularized trial prejudice.	Applying Barker de novo, the Court found the delay presumptively prejudicial and that all four Barker factors weighed for Long; conviction vacated.

Barker v. Wingo, 407 U.S. 514 (establishes four-factor speedy-trial test)
Doggett v. United States, 505 U.S. 647 (delay approaching one year is presumptively prejudicial; on presuming prejudice)
State v. Hull, 110 Ohio St.3d 183 (Ohio: speedy-trial protections apply after a conviction is vacated and case remanded)
State v. Adams, 144 Ohio St.3d 429 (discussion of presumptively prejudicial delay in Ohio)
Maples v. Stegall, 427 F.3d 1020 (distinguishes threshold triggering delay inquiry from presumption-of-prejudice analysis)