State v. Smith, 2020 Ohio 2921

John Smith was 16 at the time of the offense; the juvenile court transferred the case to adult common pleas court on June 21, 2018.
An indictment charged Smith with multiple counts (including murder) and firearm specifications; cases against Smith and co-defendant were consolidated.
Trial was set at an October 2, 2018 status conference for December 10, 2018; the trial date was journalized as set at Smith’s counsel’s request.
The State moved on November 30, 2018 to continue the December 10 trial because the lead detective had mandatory out-of-state training; the court granted the continuance and ultimately reset trial to February 4, 2019 over Smith’s objection.
Smith filed a speedy-trial motion; on February 4, 2019 Smith pleaded no contest to one murder count while preserving speedy-trial appellate rights; the trial court denied the dismissal motion and sentenced Smith to 15 years to life.
The Ninth District affirmed the conviction, finding the continuances tolled speedy-trial time as reasonable, but remanded for nunc pro tunc correction of clerical errors in the sentencing entry.

Issue	State's Argument	Smith's Argument	Held
Whether the trial court erred by denying dismissal for a speedy-trial violation under R.C. 2945.71 based on two continuances (Oct 2–Dec 10 and Dec 10–Feb 4).	Continuances tolled time: December 10 date was set at or with acquiescence of Smith’s counsel; continuance to Feb 4 was reasonable due to unavailability of a necessary witness (lead detective) for mandatory training.	Trial dates and continuances pushed trial beyond the statutory speedy-trial limits; the State failed to justify the continuance and the delay should be charged to the State.	Affirmed. Court held the October 2–Dec 10 scheduling was properly attributable to Smith or otherwise reasonably extended; the Dec 10–Feb 4 continuance was reasonable for witness unavailability and tolled speedy-trial time. Remanded for nunc pro tunc correction of clerical errors.

State v. Ramey, 132 Ohio St.3d 309 (2012) (explains strict construction of statutory tolling provisions and circumstances that may extend speedy-trial time)
State v. McRae, 55 Ohio St.2d 149 (1978) (trial court discretion to set or extend trial date beyond statutory limit when reasonable)
State v. Saffell, 35 Ohio St.3d 90 (1988) (vacation or unavailability of arresting officer can justify a reasonable continuance)
State v. Mincy, 2 Ohio St.3d 6 (1982) (ideal practice requires journalizing continuance and reasons before speedy-trial deadline)
State v. O'Brien, 34 Ohio St.3d 7 (1987) (Ohio statutory speedy-trial provisions are coextensive with constitutional speedy-trial rights)
State v. Bickerstaff, 10 Ohio St.3d 62 (1984) (juvenile speedy-trial protections begin once juvenile court transfers the case to adult court)