The Court dismissed an inmate’s additional charges because the prison warden did not notify local officials that the inmate intended to invoke his speedy trial rights.

The Court dismissed an inmate’s additional charges because the prison warden did not notify local officials that the inmate intended to invoke his speedy trial rights.

A prison warden did not follow a state law requiring he notify local officials that an inmate facing robbery charges intended to invoke his rights to a speedy trial, so the charges must be dismissed, the Supreme Court of Ohio ruled today.

In a 4-3 decision, the Supreme Court upheld a Lorain County Common Pleas Court decision that dismissed charges against Tyler Williams after a prison warden did not transmit Williams’ request for a speedy trial to the prosecutor and the trial court. The Ninth District Court of Appeals had overruled the trial court’s decision – saying Williams did not “cause” the speedy trial notice to be delivered.

Writing for the Court majority, Justice Michael P. Donnelly stated that Williams strictly complied with the requirements of R.C. 2941.401 by notifying the Lorain County Correctional Institution warden that he was invoking his speedy trial rights. Justice Donnelly explained that under the law, inmates cannot deliver speedy trial notices themselves but can request the warden to deliver the notices. Justice Donnelly wrote the Court has previously ruled that R.C. 2941.401 “does not allow a prisoner to be punished for the failures of the state,” and applied that precedent to today’s decision.

Justices Patrick F. Fischer, Melody Stewart, and Jennifer Brunner joined Justice Donnelly’s opinion.

In a dissenting opinion, Justice R. Patrick DeWine faulted the majority for substituting its own policy preferences for the plain language of the statute. He noted a 1993 U.S. Supreme Court decision analyzing a nearly identical law had summarily rejected the majority’s reading of the relevant language. In that case, the high court concluded that under the plain language of the statute, the notice of the speedy trial rights is not delivered until it is received by the prosecutor and the court handling the case. Justice DeWine also explained that the majority’s misreading of the statute will have unfortunate impacts on crime victims and prosecutors, requiring the dismissal of charges before the prosecutor has even been notified that the prisoner wishes to be brought to trial. 

Chief Justice Sharon L. Kennedy and Justice Joseph T. Deters joined Justice DeWine’s dissent.

Past Charges Reach Prison Inmate
Williams was indicted in October 2018 in Lorain County for aggravated robbery and robbery. A warrant was issued for his arrest. Before he could be arrested, he was jailed in Cuyahoga County for a separate crime. In February 2019, a Cuyahoga County trial court sentenced Williams to three years in prison.

Weeks after his sentencing, Williams was transferred to the Lorain Correctional Institution to serve his prison sentence on the Cuyahoga County conviction. In March 2019, he was notified of the pending charges against him in Lorain County from the 2018 indictment. With the assistance of the prison library, Williams completed the notice required by him under R.C. 2941.401 to invoke his speedy trial rights, and he gave it to the warden.

Under R.C. 2941.401, when a person is in prison, and a charge is pending for another offense, the inmate must be brought to trial within 180 days “after he causes to be delivered to the prosecuting attorney and the appropriate court in which the matter is pending, written notice of the place of imprisonment and a request for final disposition to be made of the matter.”

The law states that the prisoner’s request to be brought to trial within 180 days “shall be accompanied by a certificate of the warden or superintendent having custody of the prisoner” regarding the inmate’s status. The statute indicates that once the warden or superintendent receives the notice, the notice and certificate must be “promptly” sent to the prosecutor and trial court. If the case is not brought to trial within 180 days, the trial court must dismiss the charges.

Warden Does Not Transfer Notices
After Williams sent his first request to the warden, he did not receive a response. However, the Department of Rehabilitation and Correction sent a letter informing the Lorain County Sheriff’s Office of the pending charges against Williams. The letter expressed Williams’ interest in seeking a speedy trial for the robbery charges.

Williams repeated the request process again a week after not hearing from the warden. After a month without response, Williams made a third attempt to provide the written notice to the warden. The warden never sent any notices to the prosecutor or the appropriate court.

Williams was later transferred to other state prisons and completed his sentence in September 2020. After his release, he was arrested in Lorain County for the 2018 robbery charges. He filed a motion to dismiss the case based on a violation of his speedy trial rights. The trial court concluded that Williams complied with R.C. 2941.401, and dismissed the charges.

The Lorain County Prosecutor’s Office appealed the decision. In a 2-1 decision, the Ninth District reversed the trial court ruling, finding Williams did not comply with the law because he had not “caused the delivery” of the speedy trial notice to the prosecutor and trial court.

Williams appealed the decision to the Supreme Court, which agreed to hear the case.

Supreme Court Analyzed Speedy Trial Notification Law
Justice Donnelly explained that the resolution of Williams’ case depends on the law’s meaning  of “causes to be delivered.” While the Ninth District ruled that only the actual delivery to the prosecutor and court triggers the 180-day speedy trial clock, the opinion noted that the Third, Fifth, and Eighth District appeals courts have ruled in other cases that the speedy trial clock is triggered once a prisoner provides the required notice to the warden.

The Court stated that R.C. 2941.401 “does not put burdens on prisoners to deliver a written notice” beyond the explicit requirement that the materials be delivered to the warden.

The prosecutor had argued that under the U.S. Supreme Court’s 1993 Fex v. Michigan decision, the prisoner’s request had to reach the prosecutor and court to trigger the 180-day speedy trial clock. Today’s opinion noted that the Fex case dealt with a law regarding prisoners incarcerated in a state or a federal prison and facing charges in another state.

The Court majority noted that while the Michigan law on interstate cases is similar to the Ohio law at issue in Williams’ case, the two cases are based on different circumstances. The opinion stated that the U.S. Supreme Court’s decision does not control the outcome of Williams’ case. In Fex, the warden did mail the notice, but it arrived late. The issue was whether the 180-day clock started when the prosecutor received the notice or when the warden received the notice, the opinion noted. In that case, the U.S. Supreme Court ruled that the clock starts when the prosecutor and court receive the notice.

Justice Donnelly stated that the opinion today does not impact or conflict with the Fex decision. That ruling applies to cases dealing with charges in other states. For cases within Ohio, R.C. 2941.401 applies, and the law only requires the inmate to notify the warden to trigger the clock.

“When a warden fails to act, whether intentionally, inadvertently, or otherwise, we have consistently held that the consequences should inure to the state on whose behalf the warden acts. We see no reason to deviate from precedent now,” the Court concluded.

Notice Not Delivered, Dissent Maintained
In his dissent, Justice DeWine wrote the U.S. Supreme Court has answered the simple question, “Can someone cause a notice to be delivered if the notice is never actually delivered?” He responded, “The obvious answer is no.”

The dissent noted if the warden fails to comply with the obligations under the law, the prisoner might have “other remedies,” such as seeking a writ of mandamus or taking other civil actions to force the issue. However, under the law as written, the warden’s failure to send the notice does not lead to the dismissal of the charges.

The dissent stated that the majority opinion’s conclusion that the 180-day speedy trial clock is triggered when the warden receives the notice is a policy decision that is at odds with the plain language of the statute. It is self-evident, the dissent explained, that someone cannot cause something to be delivered unless delivery has actually occurred.

As a result of the majority’s failure to follow the statute, crime victims and the prosecution will suffer the consequences of the warden’s failure, the dissent explained. The state can permanently lose the right to prosecute a crime without any notice to the state, the dissent stated. The U.S. Supreme Court raised the same concern in the Fex decision, the dissent noted. Writing for the majority in that case, Justice Antonin Scalia concluded that while the inmate is deprived of speedy trial rights, the loss of the state’s right to try a person for a crime is a “significantly worse” outcome.

Justice DeWine wrote that the Ohio Supreme Court should follow the plain language of the statute, even if the majority did not like the outcome, and that policy decisions should be left to the legislature.   

“I would leave any tweaking of its language to the General Assembly,” Justice DeWine concluded.

2022-0121. State v. Williams, Slip Opinion No. 2023-Ohio-3647.

View oral argument video of this case.

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