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 involved in a burglary in Alamogordo, New Mexico, in July 1995, during which multiple items, including vehicles, tools, and firearms, were stolen. The Defendant was apprehended later that day in a stolen vehicle and fled from police during questioning. He was subsequently arrested in Texas while traveling with others in vehicles linked to the burglary (paras 3-5).
Procedural History
- District Court, February 1996: The Defendant was tried and convicted for receiving or transferring a stolen vehicle (the Lincoln Continental) in a separate case. He did not appeal this conviction (para 6).
- Magistrate Court, September 1996: A preliminary hearing was held, and the Defendant was bound over for trial on multiple charges related to the burglary (paras 6-8).
Parties' Submissions
- Defendant-Appellant: Argued that his right to a speedy trial was violated due to the 21-month delay between his arrest and trial, asserting that this delay caused prejudice and violated his constitutional rights (para 1).
- Plaintiff-Appellee: Contended that the Defendant's speedy trial right was not violated because the delay was not presumptively prejudicial, and the right only attached when the criminal information was filed in October 1996, not at the time of his arrest (paras 9-14).
Legal Issues
- Was the Defendant's right to a speedy trial violated by the 21-month delay between his arrest and trial?
Disposition
- The Court of Appeals affirmed the Defendant's convictions, holding that his right to a speedy trial was not violated (para 16).
Reasons
Per M. Christina Armijo J. (Pickard CJ. and Wechsler J. concurring):
The Court determined that the Defendant's right to a speedy trial attached when the criminal information was filed in October 1996, not at the time of his arrest in July 1995. The delay between the attachment of the right and the trial was less than six months, which was insufficient to trigger a full analysis under the four-factor balancing test established in Barker v. Wingo. The Court emphasized that the filing of a complaint in magistrate court did not meet the formal requirements to trigger the speedy trial right for felony charges. Additionally, the Defendant failed to provide authority to support his argument that the complaint was sufficient to implicate his speedy trial rights. The Court also noted that the Defendant did not separately argue the speedy trial violation for the misdemeanor count or raise issues related to the six-month rule for misdemeanors (paras 9-15).