State v. Dean

Citations

• 2022 Ohio 3105

Syllabus

The trial court did not err by denying appellants' motions to dismiss on speedy trial grounds where appellants were tried well within the necessary 45-day time limitation set forth by R.C. 2945.71(B)(1) and their right to a speedy trial was not violated, either statutorily or constitutionally, given the vast majority of the days that passed between the service of their respective summonses and the date of their trial were tolled under R.C. 2945.72(E) by appellants' numerous motions and filings. The trial court also did not err, plain or otherwise, by failing to provide appellants reasonable ADA accommodations or by not having an ADA coordinator assisting them at trial where appellants chose not to elaborate on their circumstances or identify their needs for necessary accommodation despite the trial court requesting such information from appellants on multiple occasions prior to their trial. However, although one of the appellants' criminal trespass convictions was supported by sufficient evidence and not against the manifest weight of the evidence, the other appellant's criminal trespass conviction was not supported by sufficient evidence, thereby rendering his manifest weight of the evidence argument moot, where that appellant was never warned not to be on the property.