State v. Morgan, 2017 Ohio 9142

Early-morning encounter (Apr. 2, 2016): police responded to reports of a disturbed man and a Taco Bell employee saying a man claimed he had been attacked; officers found appellant Ryan S. Morgan at the Taco Bell, agitated and suspected of drug use.
Officers went to the sister’s residence (606 ½ Cottage St.); appellant said he lived there and officers entered after obtaining purported consent from the sister’s boyfriend; in appellant’s bedroom they found syringes, a razor blade with white residue, cotton, ziplock baggies, and a glass pipe with white residue.
Appellant admitted ownership of syringes and heroin use; he denied meth use and challenged the bedroom-search consent.
Indicted on one felony count (aggravated possession of methamphetamine) and two misdemeanor counts (possession of drug abuse instruments; possession of drug paraphernalia); arrested July 26, 2016 and remained in custody throughout.
Defense filed a motion to suppress (Sept. 16, 2016); the court held a hearing Dec. 2, 2016 but did not rule until Mar. 6, 2017 (168 days after filing). Defendant moved to dismiss for speedy-trial violation on Mar. 3, 2017; trial was held Mar. 22, 2017 resulting in acquittal on the felony and convictions on the two misdemeanors.
On appeal the Fifth District reversed and entered acquittals on Counts II and III, holding the delay in ruling on the suppression motion was unreasonable and violated speedy-trial statutes.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Morgan)	Held
Whether defendant was tried within statutory speedy-trial time	Tolling events (motions, filings) justified delay; motion to suppress tolled time	Delay in ruling on suppression (168 days) was excessive; speedy-trial time expired and dismissal required	Reversed: dismissal required; convictions vacated
Whether trial court properly denied motion to suppress (consent to search)	Consent was valid; evidence admissible	Consent was invalid; suppression warranted	Moot after speedy-trial reversal

State v. Ladd, 56 Ohio St.2d 197 (recognition that speedy-trial rights are mandatory)
State v. Pachay, 64 Ohio St.2d 218 (statutory speedy-trial provisions must be strictly enforced)
State v. Arrizola, 79 Ohio App.3d 72 (delay of several months ruling on suppression was unreasonable)
State v. Saffell, 35 Ohio St.3d 90 (reasonableness of court delay depends on case-specific facts)
State v. Martin, 56 Ohio St.2d 289 (trial judges must rule on motions expeditiously)
Barker v. Wingo, 407 U.S. 514 (four-factor balancing test for speedy-trial claims)
State v. O'Brien, 34 Ohio St.3d 7 (adoption of Barker balancing in Ohio)