State v. Smith, 2011 Ohio 602

Smith was indicted for conveying an illegal drug into a detention facility (May 15, 2009).
Arrested May 18, 2009; remained jailed on $25,000 bond pending trial.
Smith pleaded not guilty; sought a jury trial after reconsidering plea options.
Trial date set; on July 6, 2009 Smith shifted to trial rather than plea; August 10, 2009 trial date set.
Two speedy-trial continuances were granted: 45 days (Aug 10 to Sept 23, 2009) and 78 days (Sept 23 to Dec 9, 2009) for witness unavailability.
Smith ultimately pleaded no contest on December 22, 2009; court sentenced him; appellate issues preserved for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the no contest plea was valid given no journalized ruling on the speedy-trial motion.	Smith preserved the speedy-trial issue by implied overruling.	Smith argues plea barred review of the speedy-trial issue due to lack of ruling.	Plea valid; speedy-trial issue properly before court.
Whether the trial court properly denied the speedy-trial dismissal based on tolling events.	Smith shows prima facie discharge; asks tolling events extend time.	State shows tolling via continuances and motions tolling equal time, so discharge not required.	Speedy-trial time tolled; discharge not required.
Whether the trial court abused its discretion by denying leave to file an untimely suppression motion.	Interest of justice required extension to file suppression.	No good cause shown for extension; waiver doctrine applied.	No abuse of discretion; no good cause shown; motion denied.

State v. Whitt, 2005-Ohio-5154 (Ohio Ct. App. 2005) (presumed overruling when no ruling shown on speedy-trial motion before trial)
Brannan v. Fowler, 100 Ohio App.3d 577 (Ohio Ct. App. 1995) (Crim.R. 12 preserves review where motion to dismiss is impliedly overruled)
State v. Hines, 145 Ohio App.3d 792 (Ohio Ct. App. 2001) (speedy-trial issues; implications for tolling)
State v. Staffin, 2008-Ohio-338 (Ohio Ct. App. 2008) (270-day speedy-trial framework; arrest date not counted)
State v. Saffell, 1990-Ohio-361 (Ohio St. 1988) (unavailability of material witness as reasonable continuance)
State v. Mintz, 1991-Ohio-59 (Ohio App. 1991) (waiver and timely filing considerations for suppression)
State v. Younker, 2008-Ohio-6889 (Ohio Ct. App. 2008) (speedy-trial time when plea occurs within limit)
State v. Butcher, 27 Ohio St.3d 28 (1986) (burden shift to state after prima facie case for discharge)
State v. Lee, 1976-Ohio St.3d 208 (Ohio St. 1976) (reasonableness of continuance under tolling)
State v. Reeser, 1980-Ohio St.2d 189 (Ohio Sup. Ct. 1980) (timeliness of state efforts in continuances)
State v. Rush, 2003-Ohio-3915 (Ohio Ct. App. 2003) (discretion in extending pretrial extensions)