State v. Washington

Citations

• 2026 Ohio 740

Syllabus

Statute of limitations; R.C. 2901.13(A)(4); John Doe indictment; rape; kidnapping. Appellant challenged convictions for two counts of rape and one count of kidnapping based on events that occurred in 1995, arguing that the State commenced its prosecution outside the applicable limitations period and that law enforcement did not act with reasonable diligence as to toll the statute of limitations. The State filed a John Doe indictment in 2014 and did not move to amend the indictment to name a defendant until 2023. However, appellant failed to raise a statute-of-limitations defense before the trial court, waiving the defense. Convictions affirmed.