Akron v. Schaffer

CourtOhio Court of Appeals
DecidedMay 29, 2026
Docket31314
StatusPublished

This text of Akron v. Schaffer (Akron v. Schaffer) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Akron v. Schaffer, (Ohio Ct. App. 2026).

Opinion

[Cite as Akron v. Schaffer, 2026-Ohio-2017.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

CITY OF AKRON C.A. No. 31314

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE JOSHUA SCHAFFER AKRON MUNICIPAL COURT COUNTY OF SUMMIT, OHIO Appellant CASE No. 24CRB 06469

DECISION AND JOURNAL ENTRY

Dated: May 29, 2026

CARR, Judge.

{¶1} Appellant, Joshua Schaffer, appeals the judgment of the Akron Municipal Court.

This Court affirms in part, reverses in part, and remands.

I.

{¶2} Due to Schaffer’s conduct on the campus of Summa Hospital on August 19, 2024,

he was charged with one count of criminal trespass in violation of Akron City Code 131.08(B)(1).

{¶3} Prior to arraignment, Schaffer filed a series of pro se motions in the trial court,

including a motion to dismiss and a motion for a continuance to obtain counsel. The trial court

denied Schaffer’s motions. A public defender was appointed and Schaffer entered a plea of not

guilty at arraignment. In the days and weeks that followed, Schaffer filed another series of pro se

motions, including multiple motions to dismiss on the basis that law enforcement violated his First

Amendment rights. While the trial court denied Schaffer’s motions to dismiss on October 23,

2024, it did not rule on Schaffer’s other pro se motions at that time. 2

{¶4} On November 1, 2024, defense counsel filed a motion to dismiss on the basis that

the City had violated Schaffer’s speedy trial rights under the Ohio Constitution as well as R.C.

2945.71(B)(1). The City filed a brief in opposition to the motion. Thereafter, the trial court issued

a journal entry denying the motion to dismiss on speedy trial grounds. The trial court further

ordered that Schaffer’s pro se motions be stricken from the record.

{¶5} The matter proceeded to a jury trial where Schaffer was found guilty of criminal

trespass. The trial court sentenced Schaffer to a 30-day jail sentence and imposed a $250 fine.

Both the jail sentence and the fine were suspended on the condition that Schaffer obey all laws for

one year. Schaffer was also ordered to complete 16 hours of community service.

{¶6} On appeal, Schaffer raises three assignments of error.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ERRED IN DENYING SCHAFFER’S MOTION TO DISMISS ON SPEEDY TRIAL GROUNDS.

{¶7} In his first assignment of error, Schaffer argues that the trial court erred in denying

his motion to dismiss on statutory speedy trial grounds.

Background

{¶8} Schaffer received his summons on the same date as the incident, August 19, 2024.

Two days later, Schaffer filed a number of pro se motions, including a motion to dismiss, a motion

for a protection order, and a motion for a continuance to retain counsel. On August 26, Schaffer

pleaded not guilty to the charge at arraignment, and a public defender was appointed on his behalf.

The pro se motions that Schaffer filed prior to arraignment were denied.1

1 While the trial court did not address the motion for a continuance prior to arraignment, the trial court denied the remaining motions on August 22, 2024. 3

{¶9} After defense counsel was appointed, Schaffer continued to file a variety of pro se

motions. Schaffer filed a pro se motion to dismiss on August 28. On September 4, Schaffer filed

another set of pro se motions, including a second motion to dismiss and a motion for a protective

order. Thereafter, on September 16, Schaffer filed yet another set of pro se motions, including a

motion for discovery and a motion to compel the attendance of a witness. A review of the file

jacket reveals a notation on October 23, which reads, “Def[endant]’s motions to dismiss are denied.

Time charged to Def[endant].” The notation does not refer to Schaffer’s other pro se filings.

{¶10} As Schaffer was in the midst of filing pro se motions, defense counsel filed a

demand for discovery on August 29, and the City delivered discovery ten days later on September

9.

{¶11} The trial court set the matter for a jury trial on October 3. On September 30, the

City filed a motion for a continuance on the basis that the assistant prosecutor would be out of

town. On October 4, the trial court granted the motion via stamp and signature. The file jacket

further contains a notation from the trial judge on October 7, which reads, “Per parties’ agreement

case cont[inued and] set for next available trial date per parties’ schedule.” The trial date was

rescheduled for October 31. The trial court subsequently continued the trial date to November 7,

“due to a congested dockets and unavailability of trial judge.”

{¶12} On November 1, defense counsel filed a motion to dismiss on the basis that the City

failed to bring Schaffer to trial within 45 days as required by R.C. 2945.71(B). Defense counsel’s

argument centered the viability of this Court’s decision in State v. Hill, 2019-Ohio-5329, ¶ 11 (9th

Dist.), where we held that pro se motions filed by a defendant represented by counsel toll the

speedy trial clock for a reasonable period of time pursuant to R.C. 2945.72(E). Defense counsel

urged the trial court to refrain from applying Hill on the basis that it conflicted with the Supreme 4

Court’s decision in State v. Martin, 2004-Ohio-5471, ¶ 32, which reaffirmed Ohio’s prohibition

against hybrid representation. Defense counsel argued that Schaffer’s pro se filings were never

properly before the trial court because Schaffer was represented by counsel at those times. Defense

counsel concluded that the only tolling event that occurred after arraignment was Schaffer’s

August 29 discovery demand, which tolled time for ten days.

{¶13} The City filed a memorandum in opposition to the motion to dismiss maintaining

that Hill was controlling. The City argued that even though hybrid representation is not permitted,

a pro se motion still acts as a tolling event.

{¶14} On the first day of trial, the trial court permitted the parties to present oral arguments

on the speedy trial issue. Schaffer again focused on the pro se filings, maintaining that those

motions were never properly before the trial court and that the trial court was under no obligation

to rule on them. Schaffer reasoned that because the filing of the pro se motions did not serve as

tolling events, the speedy trial clock had already expired. The City reiterated its position that Hill

was controlling and that Schaffer’s pro se motions served as tolling events. At the close of

arguments, the trial court denied the motion to dismiss.

{¶15} That same day, the trial court issued a journal entry denying the motion to dismiss

on the basis that, under the precedent established in Hill, Schaffer’s pro se motions tolled the

speedy trial clock. With respect to Schaffer’s pro se motions that remained pending at that time,

the trial court ordered the motions stricken from the record on the basis that Schaffer was

represented by a public defender.

Discussion

{¶16} On appeal, Schaffer contends that the trial court erred in denying his motion to

dismiss by erroneously concluding that his pro se motions tolled time for speedy trial purposes 5

given that those motions were never properly before the court. Shaffer argues that the trial court’s

reliance on Hill was misplaced, given that the Hill decision is “irreconcilable” with the Supreme

Court’s decision in Martin.

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Related

State v. Fields
2013 Ohio 4970 (Ohio Court of Appeals, 2013)
State v. Hill
2019 Ohio 5329 (Ohio Court of Appeals, 2019)
State v. Butcher
500 N.E.2d 1368 (Ohio Supreme Court, 1986)
State v. Jenks
574 N.E.2d 492 (Ohio Supreme Court, 1991)

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Akron v. Schaffer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/akron-v-schaffer-ohioctapp-2026.