State v. A.W.

2023 Ohio 3196
CourtOhio Court of Appeals
DecidedSeptember 11, 2023
Docket22AP0013
StatusPublished

This text of 2023 Ohio 3196 (State v. A.W.) 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
State v. A.W., 2023 Ohio 3196 (Ohio Ct. App. 2023).

Opinion

[Cite as State v. A.W., 2023-Ohio-3196.]

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

STATE OF OHIO C.A. No. 22AP0013

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE A.W. COURT OF COMMON PLEAS COUNTY OF WAYNE, OHIO Appellee CASE No. 2020 CRC-I 000265

DECISION AND JOURNAL ENTRY

Dated: September 11, 2023

SUTTON, Presiding Judge.

{¶1} The State of Ohio appeals the judgment of the Wayne County Court of Common

Pleas dismissing the case against Defendant-Appellee, A.W., based upon a violation of her

constitutional right to a speedy trial. This Court affirms.

I.

{¶2} On April 27, 2020, an indictment was filed charging A.W. with tampering with

records, Medicaid eligibility fraud, and the illegal use of supplemental nutrition assistance program

benefits or WIC program benefits. On April 28, 2020, the trial court set a personal recognizance

bond. A warrant was issued for A.W.’s arrest.

{¶3} A.W. was arrested on May 17, 2021, and was subsequently released on bond. On

May 19, 2021, A.W. waived arraignment and entered a plea of not guilty. On May 20, 2021, A.W.

filed a motion to dismiss alleging her constitutional rights to a speedy trial under the Ohio and

United States Constitution were violated. In so doing, A.W. relied upon the factors in Barker v. 2

Wingo, 407 U.S. 514 (1972). A.W. asserted the delay in serving her with the indictment was

presumptively prejudicial as it exceeded a year. She maintained there was no plausible

justification for the delay as A.W. lived and worked in Wayne County the entire time. A.W. also

indicated she did not delay in asserting her speedy trial rights. As to prejudice, A.W. claimed her

work as a medical assistant would be jeopardized by a conviction and the delay would impact

witnesses’ memories. The State responded in opposition and disputed how the Barker factors

should be weighed. The State maintained the factors supported denying A.W.’s motion. A.W.

filed a reply brief wherein she asserted she was aware of the investigation as early as July 2019,

thereby contributing to her anxiety. A short hearing was held on the matter. At the hearing, inter

alia, A.W. discussed the stress of having knowledge of the investigation caused her and indicated

she had to resume taking anxiety medication.

{¶4} On January 24, 2022, the trial court issued a judgment entry finding in favor of

A.W. and dismissing the case. The State has appealed, raising a single assignment of error for our

review.

ASSIGNMENT OF ERROR

THE TRIAL COURT’S JOURNAL ENTRY LACKED SPECIFIC FINDINGS PERTAINING TO THE SPEEDY TRIAL FACTORS ENUMERATED IN BARKER V. WINGO[], 407 U.S. 514 [(1972)] REQUIRING REMAND.

{¶5} In its sole assignment of error, the State argues the trial court’s failure to discuss

the Barker factors in its judgment entry warrants reversal. The State has not asked this Court to

address the merits of the trial court’s decision.

{¶6} “Review of a speedy-trial claim involves a mixed question of law and fact.

Therefore, we defer to the trial court's factual findings if they are supported by competent, credible 3

evidence, but we review the application of the law to those facts de novo.” State v. Long, 163

Ohio St.3d 179, 2020-Ohio-5363, ¶ 15.

{¶7} “The Sixth and Fourteenth Amendments to the United States Constitution and

Section 10, Article I of the Ohio Constitution, guarantee a criminal defendant the right to a speedy

trial.” State v. Ismail, 9th Dist. Medina No. 2998-M, 2001 WL 7385, *1 (Jan. 3, 2001). “A

criminal defendant’s right to a speedy trial is not limited in scope to the period following formal

arrest but extends to any delay between indictment and arrest.” (Internal quotations and citations

omitted.) State v. McCain, 9th Dist. Wayne No. 15AP0055, 2016-Ohio-4992, ¶ 9.

{¶8} “When considering whether the time between an indictment’s issuance and an

arrest violates an accused’s right to a speedy trial, appellate courts employ a two-pronged

analysis.” McCain at ¶ 10. “Under the first prong of this analysis, courts must determine whether

the accused has alleged that the interval between accusation and trial crossed the threshold dividing

ordinary from presumptively prejudicial delay[.]” (Internal quotations and citations omitted.) Id.

“Generally, a delay that approaches one year is presumptively prejudicial.” Long at ¶ 14.

{¶9} “Once the accused makes a showing of presumptive prejudice, courts must then

consider the second prong of the speedy trial analysis, which is a ‘balancing test in which the

conduct of both the prosecution and the defendant are weighed.’” McCain at ¶ 12, quoting Barker,

407 U.S. at 530. Four factors are to be considered: “Length of delay, the reason for the delay, the

defendant’s assertion of his [or her] right, and prejudice to the defendant.” Barker at 530.

{¶10} “[N]one of the four factors identified above a[re] either a necessary or sufficient

condition to the finding of a deprivation of the right of speedy trial. Rather, they are related factors

and must be considered together with such other circumstances as may be relevant. In sum, these 4

factors have no talismanic qualities; courts must still engage in a difficult and sensitive balancing

process.” Barker at 533.

{¶11} On appeal, the State only asserts the trial court erred in failing to discuss its findings

related to the Barker factors. The trial court’s judgment entry states, in relevant part:

This is a ruling on defendant [A.W.’s] motion to dismiss. The [c]ourt apologizes for the delay. The case was somehow lost in the shuffle. [A.W.] was indicted on April 27, 2020 and charged with three offenses alleged to have occurred in February-March 2018 to 2019.

[A.W.] was not served with the indictment until May 27, 2021[,] when she turned herself in. Law enforcement made no attempt to serve the indictment for over a year. [A.W.’s] address was no secret and she could have been served at any time during 2020 with minimal effort.

The Court agrees with [A.W.] that the requirements of Barker have been met.

The motion to dismiss is granted and the case dismissed.

(Emphasis added.)

{¶12} Here, the trial court’s judgment entry stated A.W. was indicted on April 27, 2020,

but was not served with the indictment until May 27, 2021, a delay of over one year. In accordance

with Long, supra, this delay is presumptively prejudicial to A.W. Moreover, this discussion

specifically addresses the first Barker factor, length of delay. The trial court also indicated the

State made no attempt to serve A.W. for over a year even though her address was “no secret” and

she “could have been served at any time during 2020 with minimal effort.” This discussion

specifically addresses the second Barker factor, reason for delay, which, here, there was none.

Further, the trial court indicated it “agree[d] with [A.W.] that the requirements of Barker have

been met.” As indicated above, in her motion to dismiss, A.W. discussed the four Barker factors,

including her assertion of her right to a speedy trial, the third Barker factor, and the resulting

prejudice due to the State’s delay, the fourth Barker factor. Further, at the motion hearing, A.W.

testified regarding the prejudicial effect the State’s delay had upon her life. 5

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Related

Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
State v. Packard
557 N.E.2d 808 (Ohio Court of Appeals, 1988)
State v. McCain
2016 Ohio 4992 (Ohio Court of Appeals, 2016)
State v. Perez
2020 Ohio 530 (Ohio Court of Appeals, 2020)
State v. Long (Slip Opinion)
2020 Ohio 5363 (Ohio Supreme Court, 2020)
State v. Wilson
2022 Ohio 2076 (Ohio Court of Appeals, 2022)

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Bluebook (online)
2023 Ohio 3196, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-aw-ohioctapp-2023.