FIRST DISTRICT
COURT OF APPEALS
THESE SUMMARIES ARE NEITHER APPROVED IN ADVANCE NOR ENDORSED BY THE COURT. THEY ARE NOT HEADNOTES OR SYLLABI. INTERESTED PARTIES SHOULD OBTAIN COPIES OF THE ACTUAL DECISIONS FROM THE CLERK OF THE COURT OF APPEALS.
DATE: Friday, September 12, 2025
CAPTION: STATE V. DAJUAN JONES
APPEAL NO.: C-240449
TRIAL NO.: 23/TRD/11750/A/C
KEY WORDS: SPEEDY TRIAL – ACTUAL PREJUDICE – PRESUMPTION OF PREJUDICE – FAILURE TO REINSTATE DRIVER’S LICENSE – SUFFICIENCY – MANIFEST WEIGHT
SUMMARY: Defendant’s constitutional speedy-trial rights were not violated despite an 11-month delay in executing arrest warrants where defendant failed to demonstrate how he was actually prejudiced by the disposal of a responding officer’s body-worn camera footage and where the circumstances surrounding the delay, including defendant’s driver’s license, which contained an outdated address, were not particularly egregious to warrant a presumption of prejudice. [See CONCURRENCE: Where an arrest warrant is executed beyond the statutory-limitation period, issues involving delays caused by a lack of reasonable diligence are better suited for statute-of-limitations analyses under R.C. 2901.03.]
Defendant’s conviction for failure to reinstate license was not supported by sufficient evidence where the State only introduced defendant’s BMV record, which indicated that, at the time of the incident, defendant was under an active suspension, and no testimony was offered explaining if another expired suspension obligated defendant to reinstate his license.
Defendant’s conviction for failure to maintain control was supported by sufficient evidence and was not contrary to the manifest weight of the evidence where an eyewitness identified defendant as the driver and retrieved defendant’s wallet at the scene of the accident.
JUDGMENT: AFFIRMED IN PART, REVERSED IN PART, AND DISCHARGED IN PART
JUDGES: OPINION by MOORE, J.; NESTOR, J., CONCURS and BOCK, P.J., CONCURS SEPARATELY.
CAPTION: WILLIAMS V. HAMILTON COUNTY PROSECUTOR
APPEAL NO.: C-240504
TRIAL NO.: A-2402974
KEY WORDS: DECLARATORY JUDGMENT — JUSTICIABILITY — DISMISSAL
SUMMARY: Where plaintiff’s complaint for a declaratory judgment did not satisfy the justiciability requirement of presenting a live controversy, the trial court did not err in dismissing the action for failure to state a claim upon which relief can be granted: a collateral attack on a criminal conviction does not present a live controversy but instead asks the court to determine whether rights that were previously adjudicated were properly adjudicated and a declaratory judgment action cannot be used as a substitute for the remedies the Ohio criminal rules and statutes provide for direct review of criminal judgments.
JUDGMENT: AFFIRMED
JUDGES: OPINION by KINSLEY, P.J.; ZAYAS and MOORE, JJ., CONCUR.