State v. Black
Annotate this CaseIn 2010, Defendant was indicted in Ashland County on charges of theft and breaking and entering. At the time, Defendant was being held in a county jail in Maryland. In 2012, the State re-indicted Defendant. Defendant filed a motion to dismiss the new indictment, arguing that his speedy-trial rights were violated because the applicable time limits under the Interstate Agreement on Detainers (IAD) - codified in Ohio Rev. Code 2963.30 - were exceeded without resolution of the charges. The trial court overruled Defendant’s motion to dismiss, concluding that the time limits under the IAD did not apply because Black was incarcerated in an out-of-state county jail and not in a state penal or correctional institution. Defendant was ultimately convicted of two misdemeanor counts of theft and one felony count of breaking and entering. The court of appeals reversed, holding that the IAD applied to Defendant even though he was incarcerated in an out-of-state county facility. The Supreme Court affirmed, holding that the term “penal or correctional institution of a party state,” as it is used in section 2963.30, includes a county jail as well as a state prison or correctional facility.
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