State v. MONTES-MATA, 253 P.3d 354

Montes-Mata was arrested in Oct 2005 and held in Lyon County jail on drug charges with no appearance bond posted.
The case underwent plea, change of counsel, and withdrawal of the plea, followed by suppression and an interlocutory appeal from the suppression ruling.
Court of Appeals affirmed the district court's suppression ruling; later, the State sought review on speedy-trial dismissal.
During an 111-day incarceration, ICE sent Form I-247 (Immigration Detainer-Notice of Action) to the sheriff, noting possible immigration proceedings against Montes-Mata.
The I-247 indicated possible detainer actions but did not purport to hold Montes-Mata in custody for pending Kansas charges.
The district court dismissed the charges under the Kansas speedy-trial statute, and the Court of Appeals affirmed; the Supreme Court affirmed the appellate court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does an ICE detainer toll the 90-day speedy-trial period?	Montes-Mata's detention was not solely for Kansas charges once detainer issued.	Detainer may toll the 90-day period when it creates a custody scenario.	Detainer did not toll the 90 days; not a custody claim.
Was Montes-Mata still being held solely on pending charges at the time of the detainer?	Detainer evidenced potential other- jurisdiction interest affecting custody status.	Detainer reflected no custodial hold on the defendant for other proceedings.	No, he was not held solely on pending charges; detainer did not alter custody status for speedy-trial calculation.

State v. Sanchez, 110 Ohio St. 3d 274 (Ohio 2006) (detainer not custody unless it imposes custodial hold; tolling denied)
State v. Adams, 283 Kan. 365 (Kan. 2007) (speedy-trial standard; de novo review for statutory issue)
State v. Brown, 64 Ohio St. 3d 476 (Ohio 1992) (custodial hold analysis for detainers and custody status)