State v. Cheatham

Citations

• 2021 Ohio 2495

Syllabus

SPEEDY-TRIAL– CONTINUANCE – WAIVER –DISCOVERY – CRIM.R. 16(K): The trial court did not err by dismissing defendant's felony charges after the state failed to try defendant within the 90-day statutory period where the source of the delay was the state's discovery violation. Where defendant sought a continuance based on the state's violation of Crim.R. 16, any delay resulting from that violation shall be charged to the state. Where nothing in the record showed that defendant explicitly waived the speedy-trial time, the reviewing court must focus on the underlying source of the delay.