Sylvania v. Murray, 2015 Ohio 5023

William F. Murray III was charged by summons with soliciting prostitution (third-degree misdemeanor); he received the summons on July 2, 2014.
Murray retained counsel; counsel filed appearance and a discovery request on July 15, 2014.
The City faxed a motion to continue and attached discovery on July 29, 2014; a supplemental report was faxed August 13, 2014.
Murray filed a motion to dismiss for speedy-trial violations on August 22, 2014; a hearing occurred August 26, 2014.
The trial court ruled the 45-day speedy-trial period was tolled by Murray’s discovery request and credited at least seven days (court found facsimile evidence showing delivery); it denied the motion to dismiss.
Murray pleaded no contest to a reduced charge of disorderly conduct and appealed, arguing speedy-trial violation and ineffective assistance of counsel.

Issue	Plaintiff's Argument (Murray)	Defendant's Argument (City)	Held
Whether the trial court erred denying motion to dismiss for speedy-trial violation	Court lacked evidence when discovery was produced; tolling should not be limited to seven days	Discovery was provided (faxed) and tolling applied from July 15 until at least July 29; 45-day deadline not expired	Denied. Court properly tolled time; speedy-trial period expired after August 30, so motion untimely
Whether counsel was ineffective for filing motion to dismiss on Aug 22 rather than waiting until trial date	Filing too early prejudiced Murray because trial was scheduled Aug 26; counsel’s timing was unreasonable	Even if counsel filed earlier, no prejudice because speedy-trial period had not expired and outcome wouldn’t change	Denied. No Strickland prejudice; counsel’s timing did not affect outcome

Adams v. State, 43 Ohio St.3d 67 (establishes speedy-trial right under Ohio law)
Brown v. State, 98 Ohio St.3d 121 (discovery demand tolls statutory speedy-trial period)
Strickland v. Washington, 466 U.S. 668 (two-prong ineffective-assistance test: performance and prejudice)