State v. Williams, 2023 Ohio 1002

Joseph L. Williams was arrested Nov. 26, 2017 and indicted Dec. 6, 2017 on two counts of murder with repeat-violent-offender specifications; he remained in jail pretrial.
Williams was additionally indicted Jan. 5, 2018 on a separate cocaine-possession charge; he later pled to that charge and received an 11‑month sentence concurrent with the murder sentence.
Multiple continuances were entered; trial ultimately began Sept. 10, 2018 (trial Sept. 10–17, 2018). Williams moved to dismiss for violation of speedy‑trial rights; the trial court denied the motion.
On direct appeal this court affirmed the convictions; Williams successfully applied to reopen the appeal limited to speedy‑trial and ineffective‑assistance (for failure to raise speedy‑trial on direct appeal).
The court independently calculated speedy‑trial time: 288 calendar days elapsed from arrest to trial; after accounting for tolling, waivers, and triple‑counting only 263 days were chargeable to the state — less than the 270‑day statutory limit — and the delay was not presumptively prejudicial under the constitutional test.
Result: trial court’s denial of the speedy‑trial motion was affirmed; appellate counsel was not ineffective for failing to raise a meritless speedy‑trial claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams's statutory speedy‑trial rights under R.C. 2945.71 were violated	State: tolling events and waivers (discovery, continuances) reduce chargeable days to under 270	Williams: he did not waive speedy trial; triple‑counting of days he was jailed should produce >270 days	Court: after tolling, waivers, and limited triple‑counting, only 263 chargeable days elapsed; no statutory violation
Whether appellate counsel was ineffective for not raising the speedy‑trial claim on direct appeal	State: counsel may decline meritless issues	Williams: prior appellate counsel should have raised the speedy‑trial claim	Court: counsel was not ineffective because the speedy‑trial claim lacked merit

State v. MacDonald, 48 Ohio St.2d 66 (triple‑count provision applies only when defendant is jailed solely on the pending charge)
State v. Adams, 43 Ohio St.3d 67 (additional charges arising from the same facts share the original speedy‑trial limitations)
State v. Baker, 78 Ohio St.3d 108 (additional crimes based on different facts do not share the same speedy‑trial computation)
State v. Parker, 113 Ohio St.3d 207 (when multiple charges arise from the same incident and share pretrial history, pretrial incarceration counts as incarceration on the pending charge)
Barker v. Wingo, 407 U.S. 514 (constitutional speedy‑trial analysis uses four‑factor balancing test)
State v. Ladd, 56 Ohio St.2d 197 (recognizes that MacDonald may be inequitable in some circumstances)