State v. Walters
2024 Ohio 3179
| Ohio Ct. App. | 2024Background
- Shane Walters was arrested on August 18, 2023, for operating a vehicle while intoxicated (OVI).
- Walters was arraigned on August 22, 2023, entered a not guilty plea, and later appealed his administrative license suspension (ALS) before withdrawing it.
- At multiple pretrial hearings, the State offered him plea deals, and Walters' counsel indicated intent to file motions to suppress evidence and in limine, eventually filing the motion 121 days after arraignment (well past the 35-day deadline).
- Walters cited counsel's caseload, case timing, impact on employment, and lack of prejudice to the State as reasons for the late filing.
- The trial court granted Walters leave to file the motions, finding good cause and no cogent argument from the State in opposition.
- The State appealed, arguing the trial court erred in granting Walters relief from waiver for untimely motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in granting relief | Walters filed for leave 85 days late, without showing sufficient good cause per the rules. | Delay was due to counsel's workload, pretrial factors, no prejudice, and interest of justice. | Trial court did not abuse its discretion in granting leave. |
| Appropriateness of standard applied (good cause/interest of justice) | Walters did not provide a memorandum or citations per rules; did not meet 'good cause' standard. | Walters presented arguments addressing both 'good cause' and 'interest of justice' standards. | Court used and applied the correct standard. |
Key Cases Cited
- State v. Blakemore, 5 Ohio St.3d 217 (abuse of discretion standard defined as more than error of judgment)
- State v. Wade, 53 Ohio St.2d 182 (timely motion to suppress required or right is waived)
- AAAA Ents. v. River Place Community Urban Redevelopment Corp., 50 Ohio St.3d 157 (abuse of discretion is unreasonable when unsupported by sound reasoning)