State v. Knight

In State v. Knight, Greene App. No. 03-CA-14, 2005 Ohio 3179, the Court held that a defendant's filing of a discovery request did not toll the speedy trial time when the State had preemptively complied with the defendant's request (i.e., the State had provided the requested discovery before the request was made). The Court stated: "On May 6, 2002, Defendant timely filed his request for discovery. Ordinarily, that demand would toll the speedy trial time for the reasonable period of time necessary for the State to respond. Brown, supra. However, the State had already filed its 'Rule 16 Compliance' on May 1, 2002. Consequently, Defendant's request for discovery could not divert the prosecutor's attention from preparing the case for trial, Brown, supra, because the State had already provided discovery. Therefore, Defendant's May 6, 2002, request for discovery did not toll the speedy trial time." Id. at P18.