David Stiles, Jr. v. Texas

This Court held in Barker v. Wingo, 407 U.S. 514 (1972) that a speedy trial analysis is triggered by a delay of eight months. This Court held in Doggett v. United States, 505 U.S. 647 (1992) that if the government’s negligence causes an excess delay six times longer than the eight months required to trigger a speedy trial analysis, and the presumption of prejudice is neither extenuated nor persuasively rebutted, the defendant is entitled to relief. The court below was confronted with a delay of four years and five months (more than six times longer than the eight months required to trigger a speedy trial analysis) between arrest and trial, yet the court below held that the Appellant was required to demonstrate prejudice rather than the government rebut the prejudice presumption. This holding leads to the question of whether a defendant is required to demonstrate prejudice on a speedy trial claim involving a presumptively prejudicial delay of four years and five months between arrest and trial? How much delay is excess delay under Doggett which then requires the government to rebut the prejudice presumption?