State v. Reece
2017 Ohio 222
| Ohio Ct. App. | 2017Background
- In 1992 Reece was indicted in Montgomery County, Ohio, on multiple counts of rape and gross sexual imposition.
- In April 1993 he was arrested and prosecuted in Michigan for armed robbery, pleaded guilty, and received a 10–20 year Michigan sentence.
- Reece was extradited to Ohio in August 1997; on October 17, 1997, after counsel raised a speedy-trial complaint, he pleaded no contest to one rape count and one gross-sexual-imposition count under a plea agreement and was sentenced (terms to run concurrent with each other and with his Michigan sentence).
- Reece did not appeal the denial of his speedy-trial contention after the 1997 plea. He later filed a pro se motion in 2011 to withdraw his plea asserting an Interstate Agreement on Detainers (IAD) violation; the trial court denied it and Reece did not appeal.
- In July 2015 Reece filed a motion to vacate his conviction again arguing IAD and Ohio speedy-trial statute violations; the trial court denied the motion without a hearing, and Reece appealed.
- The appellate court affirmed, concluding Reece’s claims were barred by res judicata and, alternatively, that the IAD/time limits did not apply as he failed to invoke Article III and the applicable Article IV period had not expired before his plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Reece was denied his speedy-trial rights under Ohio law (R.C. 2945.71) | State: No violation; applicable IAD periods either not triggered or were complied with | Reece: Delay from 1992 indictment to 1997 trial violated speedy-trial rights | Overruled — claims barred by res judicata; alternatively no statutory/IAD violation because Article III was not invoked and Article IV period had not expired before plea |
| Whether the trial court erred by denying an evidentiary hearing on the motion to vacate | State: No hearing required—Reece submitted insufficient evidence to show IAD invocation or statutory violation | Reece: Hearing required to present evidence that IAD and speedy-trial rights were violated | Denied — trial court properly required evidentiary support; Reece failed to show he invoked Article III or otherwise met burden, so no hearing was necessary |
Key Cases Cited
- State v. Szefcyk, 77 Ohio St.3d 93, 671 N.E.2d 233 (res judicata bars collateral attack on claims that were or could have been raised at trial or on direct appeal)
- Cuyler v. Adams, 449 U.S. 433 (1981) (describing purpose and mechanics of the Interstate Agreement on Detainers)
- State v. Mourey, 64 Ohio St.3d 482, 597 N.E.2d 101 (IAD Article III procedures and the 180-day trial period when the prisoner initiates the request)
- State v. Braden, 197 Ohio App.3d 534, 968 N.E.2d 49 (if IAD is properly invoked, its timing controls over state speedy-trial statute)