State v. McIntyre, 2016 Ohio 5363

In July 2014 McIntyre allegedly committed two first-degree misdemeanors (receiving stolen property and theft); complaints were filed Aug. 28, 2014 but warrants were not served.
While incarcerated on unrelated felony convictions, McIntyre filed an R.C. 2941.401 request (Apr. 10, 2015) for final disposition; the court dismissed the municipal complaints without prejudice (May 5, 2015).
After McIntyre’s release, the state refiled the misdemeanor complaints and McIntyre was served with summonses on July 8, 2015.
Trial was scheduled for Oct. 1, 2015; on that date McIntyre moved to dismiss claiming statutory and constitutional speedy-trial violations; his briefing emphasized the statutory claim.
The municipal court denied the motion; McIntyre pleaded no contest to receiving stolen property (theft dismissed) and was convicted and sentenced.
On appeal the Fourth District affirmed, holding (1) the R.C. 2945.71 90-day statutory period began upon service (July 8, 2015) and had not expired when McIntyre moved to dismiss, and (2) the constitutional speedy-trial claim failed after Barker-factor balancing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2945.71’s 90-day speedy-trial clock began when McIntyre requested disposition while incarcerated (Apr. 10, 2015) or upon service of process	McIntyre: his 4/10/15 demand constituted the functional equivalent of arrest, so statutory clock began then	State: statute starts only on actual arrest or service of summons; no service/arrest occurred in the initial filing	Held: Statutory clock did not start until service on refiled complaints (July 8, 2015); 90 days had not run when he moved to dismiss
Whether the post-complaint delay violated the Sixth Amendment right to a speedy trial	McIntyre: ~12-month delay from alleged offenses (July 2014) to service (July 2015) was unreasonable and presumptively prejudicial	State: pre-complaint delay (to Aug. 2014) is not within Sixth Amendment speedy-trial period; much of the remaining delay resulted from McIntyre’s incarceration on unrelated convictions and caused negligible prejudice	Held: Although delay approached presumptive prejudice, Barker factors (length, reason, assertion, prejudice) weighed against relief; no constitutional violation

Barker v. Wingo, 407 U.S. 514 (1972) (establishes four-factor balancing test for constitutional speedy-trial claims)
Doggett v. United States, 505 U.S. 647 (1992) (delay approaching one year may be presumptively prejudicial)
State v. Blackburn, 118 Ohio St.3d 163 (2008) (discusses constitutional and statutory speedy-trial rights under Ohio law)
State v. Adams, 144 Ohio St.3d 429 (2015) (recites Barker factors and Ohio approach to constitutional speedy-trial analysis)
State v. Triplett, 78 Ohio St.3d 566 (1997) (prejudicialness of delay may be negligible absent pretrial incarceration or disruption)