Public-domain · open source
OpenJurist

43 Ohio St. 3d 67

State v. Adams

Ohio Supreme Court

Decided May 17, 1989

Ohio Supreme Court · decided 1989-05-17

Key passage — most relied on by later courts

“[w]hen an accused waives the right to a speedy trial as to an initial charge, this waiver is not applicable to additional charges arising from the same set of circumstances that are brought subsequent to the execution of the waiver.”

quoted by 16 later decisions, including State v. Clark, Unpublished Decision (3-8-2006), City of Akron v. Hatcher, 24346 (3-31-2009)

“The General Assembly has chosen to enforce the speedy trial statutes by providing an accused with a right to dismissal of charges upon timely motion, when not accorded trial within the statutory time. It was not the General Assembly’s sole purpose in enacting the speedy trial statutes to reward those accused of criminal conduct for a prosecutor’s lack of diligence. Concededly, an accused has a valid interest in, and an independent constitutional right to, a speedy trial. However, in construing the speedy trial statutes, this court also recognizes the public’s interests not only in the prompt adjudication of criminal cases, but also in obtaining convictions of persons who have committed criminal offenses against the state. Consistent with these interests, we hold that, where a prosecutor obtains a felony indictment, based upon the same conduct as was a previously nolled, lesser-included misdemeanor charge, the time within which the accused shall be brought to trial pursuant to [the Ohio speedy trial act] consists of whatever residue remains from the 270-day period [required for trial in a felony case] after deducting the speedy trial time expended prior to the nolle prosequi. Such a holding adequately protects the accused’s statutory rights.”

quoted by 1 later decision, including State v. Sumstine

Relies on State v. Pudlock · State v. Bonarrigo

Good law ✅— No negative treatment on recordhow we know

Decided 1989-05-17

How this case has been cited

Cited by 326 later decisions — most recently March 2026 · most notably State v. Underwood (2010), State v. Homan (2000)

326 state decisions

134019891990200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Holmes, J.,

¶1dissenting. The syllabus law in this case should state that when an accused waives the right to a speedy trial as to an initial charge, this waiver is applicable to subsequent, additional charges arising from, and inherently within, the same set of facts and circumstances as the initial charge. This court has long preserved the concept that “an accused has a valid interest in, and an independent constitutional right to, a speedy trial.” State v. Bonarrigo (1980), 62 Ohio St. 2d 7, 11, 16 O.O. 3d 4, 6, 402 N.E. 2d 530, 534. “However, in construing the speedy trial statutes, this court also recognizes the public’s interests not only in the prompt adjudication of criminal cases, but also in obtaining convictions of persons who have committed criminal offenses against the state." (Emphasis added.) Id. at 11, 16 O.O. 3d at 6, 402 N.E. 2d at 534-535. Because the majority has failed to recognize, much less consider, this countervailing public interest, I must respectfully dissent.

¶2R.C. 4511.19(A)(1) and (3), under which the appellant was serially charged below, provide as follows:

“(A) No person, shall operate any *71vehicle, streetcar, or trackless trolley within this state, if any of the following apply:
“(1) The person is under the influence of alcohol, a drug of abuse, or alcohol and a drug of abuse;
…
“(3) The person has a concentration of ten-hundredths of one gram or more by weight of alcohol per two hundred ten liters of his breath; ….”

¶3Although subsections (1) and (3) are separate offenses, they overlap and each of them relates to prohibiting alcohol-impaired persons from operating motor vehicles within Ohio. It is precisely this similarity which prevents the state from dismissing the initial charge near the end of the ninety-day period and filing a new charge under a different subsection, thereby enlarging the time for trial. To allow such a practice would impermissibly “undercut the implementation of the ‘speedy trial’ provisions … State v. Pudlock (1975), 44 Ohio St. 2d 104, 106, 73 O.O. 2d 357, 358, 338 N.E. 2d 524, 525. That did not occur in this case, and the state does not contest the fact that because the second charge stemmed from the original facts which gave rise to the initial charge, the same ninety-day period also applied to such second charge, as held by the majority.

¶4But by the same logic, and contrary to the majority’s position, there is every reason to conclude that the defendant and his counsel would be aware, upon the initial charge, that other charges reasonably inclusive within the facts of the occurrence could be charged to the defendant. Therefore, it should be determined that appellant’s general waiver would be inclusive of these later, timely filed charges.

¶5Applying appellant’s prior waivers to the subsequent charge based on the same facts does not frustrate appellant’s speedy trial rights. The record reflects that appellant was arrested on July 12, 1986. Six days later, appellant executed the first of a series of waivers of his speedy-trial rights, extending from July 18, 1986 until August 1, 1986. On July 21, appellant requested a pretrial conference, scheduled for August 14, 1986, thus further extending the speedy-trial time. R.C. 2945.72(E) and (H). On August 14, appellant requested an additional pretrial conference, and executed a written waiver of speedy-trial time until September 17, 1986. On September 17, appellant requested a trial date, and executed another writtén waiver extending until the trial date, October 22,1986. Thus, appellant knowingly, voluntarily and intelligently waived his speedy-trial time from July 18,1986 until October 22,1986 — a total of ninety-six days. At this point, only six days were chargeable to the state.

¶6Following the nolle and immediate filing of new charges here, appellant’s speedy-trial guarantee remained in exactly the same status as it was prior to the first waiver. The state had gained no additional time, having eighty-four days remaining to bring appellant to trial. Any extension of time related solely to the tactical actions of appellant. Although the better practice would be to fully charge the defendant with all relevant offenses at the time of his arrest or initial indictment, where possible, the public’s interests, stated above, should not be frustrated by the actions of the defendant when the state must, for reasons beyond its control, subsequently charge the defendant on a related offense.

¶7For all the foregoing reasons, the trial court’s denial of appellant’s motion to dismiss pursuant to R.C. 2945.73 was proper. Thus, I dissent.

Moyer, C.J., concurs in the foregoing dissenting opinion.
/43/ohiost3d/67 · .json · Public domain