State v. Stevens, 2014 Ohio 4875

Stevens was investigated for viewing child pornography; police seized five computers and other storage items from his home on December 1, 2011.
Stevens confessed to viewing/downloading child pornography over the prior two to three years and claimed he was the sole user of his computer.
Complaint filed in Bellefontaine Municipal Court on December 6, 2011; Stevens bonded and bound over to the Logan County Court of Common Pleas.
Two computers were tested by BCI with no illegal images; charges were dismissed April 4, 2012, but other computers were later tested in 2013 revealing child pornography.
Indictment for six counts of illegal use of a minor in nudity-oriented material and three counts of pandering sexually oriented material was filed July 9, 2013; Stevens moved to dismiss for speedy-trial violation on October 8, 2013.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether delay violates speedy-trial rights	Stevens argues delay was prejudicial and violates speedy trial rights.	State contends no prejudice or legally cognizable delay during pending proceedings; any delay during non-pending periods is irrelevant.	Not violated; delay not prejudicial and many delays occurred when no charges were pending.

Barker v. Wingo, 407 U.S. 514 (1972) (speedy-trial four-factor balancing test)
Doggett v. United States, 505 U.S. 647 (1992) (presumptive prejudice threshold in Barker analysis)
State v. Triplett, 78 Ohio St.3d 566 (1997) (weights for delay reasons in Barker analysis)
Ollivier, 178 Wash.2d 813 (2013) (requires actual prejudice proof; not all delays presumptively prejudicial)
Serna-Villarreal, 352 F.3d 225 (5th Cir. 2003) (post-indictment delay and presumptive prejudice thresholds; context-specific)