This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- The Defendant was charged with two counts of aggravated battery with a deadly weapon and one count of child abuse following a 2013 incident where she allegedly drove her car at two adult women and three minor children during a neighborhood party. Nineteen months after her arrest, the district court dismissed the charges, citing a violation of her Sixth Amendment right to a speedy trial (paras 2-3).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Plaintiff-Appellant (State): Argued that the Defendant's constitutional right to a speedy trial was not violated and sought reversal of the district court's dismissal of charges (para 1).
- Defendant-Appellee: Asserted that the length of delay was substantial, the reasons for the delay rested almost entirely with the State, she properly asserted her right to a speedy trial, and she was prejudiced as a result of the delay (para 15).
Legal Issues
- Whether the Defendant's Sixth Amendment right to a speedy trial was violated.
Disposition
- The Court of Appeals reversed the district court's dismissal of the Defendant's charges and remanded for further proceedings, holding that the Defendant's constitutional right to a speedy trial was not violated (para 34).
Reasons
-
Per M. Monica Zamora, with Julie J. Vargas and Stephen G. French concurring, the court applied the four-factor test from Barker v. Wingo to determine the violation of the right to a speedy trial. The court found that the length of delay (nineteen months) was presumptively prejudicial but only weighed slightly against the State. The reasons for the delay were attributed to both parties and neutral factors, ultimately weighing in favor of the State. The Defendant's assertion of her right to a speedy trial was recognized but deemed not forceful or vigorous, weighing only slightly in her favor. Lastly, the Defendant failed to establish particularized or undue prejudice from the delay, which did not weigh in her favor. Balancing these factors, the court concluded that the Defendant's right to a speedy trial was not violated (paras 5-33).
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