State v. King

The principal query before us is whether a defendant’s oral waiver of speedy trial rights, which does not appear on the record, is effective. In the absence of such a waiver we also consider whether a trial court may sua sponte continue a defendant’s trial beyond the expiration of the time limit prescribed in R.C. 2945.71 for bringing a defendant to trial, without a journal entry explaining the reasons for the continuance. For the reasons that follow, we hold that a defendant’s waiver of his or her right to a speedy trial must be either written or made on the record in open court. We also…