State v. Graham

Citations

• 2019 Ohio 2020

Syllabus

Speedy trial timetable of first indictment does not govern charges in second indictment arising from episodes different from those alleged in first indictment, but does apply to charges in the second indictment that mirror those in the first. A time waiver executed as to the first indictment, and before the second, significantly more elaborate indictment has issued, does not toll time on charges in the second indictment after its issuance. By statute, the state was out of time on two of the 21 counts on which defendant was sentenced. There was no constitutional violation of defendant's speedy trial rights as to the remaining 19 counts.