State v. Brown

Citations

• 2026 Ohio 1622

Syllabus

Alleged defect in municipal court complaint did not render judgment of conviction and sentence invalid, because appellant was tried and convicted on the charge contained in a grand jury indictment filed in the common pleas court, not on the charge contained in the municipal court complaint. Appellant's statutory right to a speedy trial was not violated, because although more than 270 days passed between his arrest and trial, fewer than 270 days were attributable to the state due to tolling and waiver. Appellant's constitutional right to a speedy trial was not violated because although the length of delay was presumptively prejudicial, consideration of the balancing factors weighed against finding a constitutional violation.