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52 Ohio App. 3d 99

557 N.E.2d 808

State v. Packard

Ohio Court of Appeals

Decided August 15, 1988

Ohio Court of Appeals · decided 1988-08-15

Good law ✅— No negative treatment on recordhow we know

Decided 1988-08-15

How this case has been cited

Cited by 11 later decisions — most recently September 2023

11 state decisions

8019881990200020102020decided

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.

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Young, J.,

¶1 dissenting. R.C. 2901.13 provides that a prosecution is not commenced upon issuance of a warrant, summons, citation or other process, unless reasonable diligence is exercised to execute the same. The warrant was issued in this case in August 1984. The state failed to introduce any evidence at the hearing on appellee’s motion to dismiss of any reasonable diligence to execute the warrant. Appellee was not arrested until October 1987, a period of thirty-eight months after the issuance of the original warrant. I agree with the trial court’s finding that the state failed to show that it had exercised reasonable diligence and that the state failed to bring appellee before the court without unreasonable delay.

¶2 I feel that the majority has failed to grasp the distinction between commencing an action within the statute of limitations and the duty of the state to exercise reasonable diligence to bring a defendant before the court without unreasonable delay. Upon the filing of the motion, as in this case, the state must present evidence of the exercise of reasonable diligence. The state failed to present such evidence.

¶3 I would affirm the decision of the trial court, and therefore I dissent.

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