State v. Taylor, 2015 Ohio 2919

On Aug. 31, 2012 Trooper Day stopped and arrested Taylor; the traffic citation included a handwritten notation “POSSESSION OF DRUGS F5.” Taylor was jailed Aug. 31–Sept. 4, 2012 and pleaded guilty to the traffic offense on Sept. 10, 2012.
Nearly a year later the State filed a county-court charge (Sept. 3, 2013) for attempted possession (misdemeanor) and a grand jury indicted Taylor Dec. 12, 2013 for aggravated possession (felony).
Taylor moved to dismiss the felony indictment on Jan. 14, 2014, asserting a violation of his speedy-trial rights under R.C. 2945.71 (270‑day rule for felonies, triple-count for jail time).
The trial court granted the motion and dismissed the indictment; the State appealed, arguing the speedy‑trial clock should run from the charging date (Sept. 3, 2013), not the arrest date (Aug. 31, 2012).
The Fourth District affirmed: because the later felony arose from the same facts as the 2012 arrest (and Taylor was incarcerated then), computation of R.C. 2945.71 time began at the Aug. 31, 2012 arrest and more than 270 days elapsed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does R.C. 2945.71(C) speedy‑trial time start for the Dec. 2013 indictment?	State: time starts on formal charging date (Sept. 3, 2013); arrest alone doesn't start the clock unless held pending charges.	Taylor: time starts at arrest (Aug. 31, 2012) because arrest was for same subject matter and he was jailed.	Court: Held for Taylor — clock began at the Aug. 31, 2012 arrest; more than 270 days elapsed.
Whether time while defendant was jailed Aug. 31–Sept. 4, 2012 counts (triple‑count)	State conceded those days count against it.	Taylor relied on those jail days to amplify elapsed time.	Court: Accepted concession and counted jail days (triple count).
Whether subsequent indictment arising from same facts restarts/tolls speedy‑trial period	State: subsequent charging controls; earlier period between arrest and later charging shouldn't be counted.	Taylor: subsequent charges arising from same facts are subject to the original speedy‑trial constraints.	Court: Followed precedent holding later charges based on the same incident do not reset/toll the original speedy‑trial period.
Whether State proved statutory tolling or exceptions to avoid dismissal	State: argued timeline excluding pre‑charging period avoids violation.	Taylor: argued no tolling or exceptions were shown.	Court: State failed to meet burden to show tolling/exceptions; dismissal affirmed.

State v. Azbell, 112 Ohio St.3d 300 (court explained an arrest that leads to immediate release without being held to answer does not always commence speedy‑trial time)
State v. Broughton, 62 Ohio St.3d 253 (addresses computing time between dismissal and reindictment when defendant not jailed or on bail)
State v. Baker, 78 Ohio St.3d 108 (subsequent charges arising from same facts are subject to the speedy‑trial constraints of the original charge)
Marion v. United States, 404 U.S. 307 (Supreme Court discussion that invocation of speedy‑trial protection may not await formal indictment)
State v. Parker, 113 Ohio St.3d 207 (clarifies that later charges based on the same incident do not toll speedy‑trial time for those charges)