State v. Ramey
132 Ohio St. 3d 309
| Ohio | 2012Background
- State v. Ramey concerns whether a co-defendant’s pretrial suppression motions toll the speedy-trial clock automatically.
- Ramey and codefendant Keeton were jointly indicted on multiple counts; Keeton filed suppression-related motions, Ramey did not.
- Ramey was jailed pending trial and trial occurred 118 days after arrest, beyond the 90-day speedy-trial limit.
- Second indictment for weapon under disability arose from the same facts as the first indictment.
- Second District held that Keeton’s suppression motions tolled time for the first indictment but not the second, and that timing for the second was not tolled.
- The Supreme Court reverses, holds no automatic tolling from co-defendant’s motions, and remands to assess reasonableness under RC 2945.72(H).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do co-defendant’s pretrial motions toll the speedy-trial clock automatically? | Ramey | Ramey | No automatic tolling; must apply RC 2945.72(H) for reasonableness. |
| Was the trial continuance properly tolling under RC 2945.72(H)? | Keeton’s motions justify tolling | Acquiescence in trial date by defense counsel; continuance must be reasonable | Remand to determine if the setting beyond the period was reasonable. |
| Did Ramey waive speedy-trial rights? | No effective waiver | Waiver implied by conduct | No written or open-court waiver found; rights preserved. |
| Is the continuance under RC 2945.72(H) reviewable for reasonableness based on the record? | Record supports tolling | Need explicit reasons for delay | Remand for reasonableness determination on existing record. |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (speedy-trial framework; justification for delay must be balanced)
- State v. King, 70 Ohio St.3d 158 (1994) (waiver must be in record to be effective)
- State v. O’Brien, 34 Ohio St.3d 7 (1987) (writing/open-court waiver required for valid waiver)
- State v. Hughes, 86 Ohio St.3d 424 (1999) (speedy-trial rights intertwined with statutory timing)
- State v. Singer, 50 Ohio St.2d 103 (1977) (strict compliance with statutory time limits)
- State v. Davis, 46 Ohio St.2d 444 (1976) (strict application of 90-day rule; continuances must be reasoned)
- State v. Mincy, 2 Ohio St.3d 6 (1982) (Mincy rule on journal-entry continuances and reasonableness)
- State v. Lee, 48 Ohio St.2d 208 (1976) (exhaustive tolling list; strict construction)
- State v. Davis (syllabus), 46 Ohio St.2d 444 (1976) (syllabus on reasonableness of continuances)