City of Bryan v. Knapp

Crim. R. 12(E) provides: “A motion made before trial other than a motion for change of venue, shall be timely determined before trial. Where factual issues are involved in determining a motion, the court shall state its essential findings on the record.” (Emphasis added.) In ruling on Knapp’s motion for discharge, the trial court on request by the *65defendant was required to determine factual issues concerning the reasons for delay of the trial. Crim. R. 12(E) mandates that the court state its essential findings on the record.1 Without such findings, neither the court of appeals nor this court…