State v. Hill

Citations

• 2025 Ohio 4565

Syllabus

SIXTH AMENDMENT — SPEEDY TRIAL — MOTION TO DISMISS: Defendant's Sixth Amendment speedy-trial rights were violated by the State's two-and-a-half-year delay between charging defendant with misdemeanor theft and arresting defendant for the theft where the State knew defendant's address the entire time, made no effort to serve her with the warrant, and failed to rebut the presumption that the lengthy delay prejudiced defendant. [See CONCURRENCE: Where the State negligently allowed enough time to pass between the filing of charges and arresting defendant that the statute of limitations had lapsed, the State cannot rebut the presumption that defendant was prejudiced by the delay.]