State v. Nichols, 2013 Ohio 308

Nichols was convicted in Nichols I of disseminating material harmful to juveniles and tampering with evidence, later sentenced to prison.
A capias issued April 19, 2011 forced Nichols’ appearance for Nichols I sentencing; he was taken into custody that day.
In April 2012 Nichols was indicted for failure to appear in the present case, based on his failure to appear at Nichols I sentencing.
Nichols remained incarcerated pending the present case; the precise custody status related to Nichols I and its disposition is unclear.
A new judge was assigned June 5, 2012 after a June 1, 2012 recusal; the speedy-trial clock was restarted.
Nichols filed a motion to dismiss on speedy-trial grounds (June 13, 2012) and a discovery request (July 20, 2012); he pled no contest on August 23, 2012, yielding a speedy-trial-resolved outcome within 270 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nichols’ speedy-trial rights were violated	Nichols argues clock started April 19, 2011.	Clock started April 12, 2012 when indictment issued; capias not a charge.	Speedy-trial time not violated; indictment date controls; case resolved within 270 days.

State v. Mincy, 2 Ohio St.3d 6 (Ohio 1982) (speedy-trial timeline and burden on state)
State v. Sanchez, 110 Ohio St.3d 274 (2006) (tolls for days in custody; triple-count rule context)
State v. Azbell, 112 Ohio St.3d 300 (2006) (charge pending when formally charged; start of speedy-trial clock)
State v. Bickerstaff, 10 Ohio St.3d 62 (1984) (time not included for motions to dismiss)
Brecksville v. Cook, 75 Ohio St.3d 53 (1996) (strict construction of speedy-trial statutes against the state)