State v. Sheets

Citations

• 2025 Ohio 355

Syllabus

VIOLATION OF CIVIL PROTECTION ORDER - R.C. 2919.27 - STATUTORY SPEEDY TRIAL - R.C. 2945.71 - CHARGING COMPLAINT - SUFFICIENCY OF EVIDENCE - APP.R. 9: Although misdemeanor trial far exceeded the 90-day speedy trial time period prescribed by R.C. 2945.71(B)(2), defendant's failure to timely file a motion to dismiss based on a speedy-trial violation or otherwise raise issue in the trial court precludes her from raising it, for the first time, on appeal since the state had no reason or opportunity to argue and present evidence supporting the tolling or extending of the statutory speedy trial period. Defendant presents claims about accuracy of information contained in the officer's complaint charging her with violating a civil protection order, but she did not challenge the validity of the complaint in the trial court, does not argue the complaint failed to meet the requirements of Crim.R. 3 on appeal, has not raised a challenge to the sufficiency of the evidence supporting her conviction, and failed to submit a transcript of the jury trial and exhibits presented at her trial for appellate review. As such, we presume the regularity of the proceedings and the validity of the judgment in the trial court. Judgment affirmed.