State v. Payne, 2014 Ohio 4326

Payne was arrested March 26, 2011 after a domestic dispute observed by a State Trooper on I-90.
A detainer from unrelated federal charges led to Payne’s transfer into federal custody and placement in Lake County jail.
Payne missed a April 7, 2011 preliminary hearing; a capias was issued, and he remained in federal custody through November 2011.
He was later imprisoned in Maryland; the State did not file any detainer or petitions to secure his presence until 2012.
Payne waived the preliminary hearing on July 3, 2012; the case was bound over to the Lorain County Grand Jury, which indicted him on multiple counts on August 16, 2012.
The State filed a writ of habeas corpus ad prosequendum in November 2012; Payne was arraigned January 25, 2013; a speedy-trial motion followed in January 2013.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State's failure to exercise diligence tolled speedy-trial time.	State argues 2945.72(A) tolls time and IAD supports tolling while Payne was unavailable.	Payne contends the State did not secure his presence within 270 days and thus violated speedy-trial rights.	Speedy-trial rights violated; dismissal affirmed.

Alabama v. Bozeman, 533 U.S. 146 (2001) (IAD detainer mechanism manuals expeditious disposition)
Murray v. District of Columbia, 826 F.Supp. 4 (D.D.C. 1993) (IAD applies to prisoners in custody not pretrial detainees)
Hill v. New York, 528 U.S. 110 (2000) (IAD liberally construed; detainers trigger 180-day window)
State v. Centafanti, 120 Ohio St.3d 275 (2008) (IAD-related procedures do not apply to federal custody deterrents when not under state commitment)
State v. Barrett, 2010-Ohio-5139 (8th Dist. 2010) (R.C. 2941.401 does not apply to federal-custody scenarios)
State v. Stowe, 2010-Ohio-4646 (5th Dist. 2010) (IAD considerations in detainer context; timely disposition mechanics)
State v. Howard, 79 Ohio App.3d 705 (8th Dist. 1992) (Distinguishes detainer tolling in certain circumstances)