State v. Stokes, 952 N.E.2d 1192

Stokes was charged in Mason Municipal Court with six counts of unauthorized use of a motor vehicle (Dec. 21, 2007 indictment).
Arrest warrant issued Aug. 29, 2007; warrant recalled Sept. 10, 2007 when counsel entered an appearance.
Stokes appeared Sept. 13, 2007, signed a speedy-trial waiver, received the complaint, and provided an address on Bercliff Avenue.
Stokes waived preliminary hearing on Oct. 9, 2007 and agreed to be bound over for indictment.
Indictment filed Dec. 21, 2007; attempts to serve Stokes at the Bercliff Avenue address failed in Jan. 2008; notice of failure of service issued Jan. 18, 2008.
Stokes was not arrested in Ohio until Jan. 4, 2010 in Florida; he was arraigned Jan. 6, 2010 and trial was set for Apr. 15–16, 2010; prior to trial, he moved to dismiss based on speedy-trial rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 270-day speedy-trial period was violated	Stokes argues a statutory speedy-trial violation occurred	State contends delay was not chargeable due to defendant's actions	No violation; period excluded due to defendant's neglect in providing a reliable address.
Whether delay was extended under R.C. 2945.72(D) for neglect by the accused	Stokes’s neglect caused the delay	State asserts diligent efforts and defendant's neglect extended time	Delay attributed to Stokes; statutory time extended; trial period properly excluded.

Barker v. Wingo, 407 U.S. 514 (1972) (constitutional speedy-trial framework governs analysis in mixed law-fact cases)