State v. Miles, 2013 Ohio 4272

On Dec. 19, 2011, Deputy Schismenos stopped Richard Miles for traffic violations; officers smelled marijuana, a K-9 alerted, and marijuana and cocaine were found in the car.
Miles was indicted for possession of cocaine and arrested without bail that same day.
Miles requested discovery (Jan. 13); received it Jan. 27; filed a motion to suppress on Feb. 21; suppression hearing held Mar. 30.
The trial court did not issue its suppression ruling until June 11 (73 days after the hearing); Miles alleged the delay caused a speedy-trial violation under R.C. 2945.71.
Additional continuances were requested by Miles (new evidence, new counsel); parties ultimately scheduled trial for Sept. 24. The trial court denied Miles’s motion to dismiss for speedy-trial violation; Miles was convicted and sentenced; he appealed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Miles)	Held
Whether Miles’s speedy-trial rights under R.C. 2945.71 were violated	Most delays were caused by Miles; the period while the motion to suppress was pending does not count toward the statutory limit because the court ruled within a reasonable time	The trial court’s unexplained delay in ruling on the suppression motion (Mar. 30–June 11) should be charged to the State and causes the 90-day limit to be exceeded	Court held suppression-motion tolling applied and the court disposed of the motion within a reasonable time; no speedy-trial violation

State v. Martin, 56 Ohio St.2d 289 (1978) (trial judge must rule on defense motions as expeditiously as possible to honor speedy-trial spirit)
State v. Beam, 77 Ohio App.3d 200 (11th Dist. 1991) (120-day rule provides an outer bound for reasonable time to rule on motions; 109-day delay was acceptable)