Brock v. State, 293 Ga. 156

Brock was arrested for the fatal fire at a Atlanta rooming house that killed James Lockett (injuries occurred Jan 29, 2003; Lockett died Feb 23, 2003).
Lockett’s rooming house fire started around 7:30 a.m. in Dixon’s room; evidence included ignitable liquid and a lighter fluid can missing cap.
Brock was indicted March 31, 2009 for malice murder, two counts of felony murder, two counts of aggravated assault, and one count of first-degree arson; some counts were later dismissed for SOL issues.
Trial occurred March 8, 2011; Brock was convicted of malice murder and two counts of felony murder; life sentence for malice murder; other counts vacated.
Brock presented an alibi defense; witnesses testified he was at his sister’s apartment early that morning.
Brock raised the speedy-trial claim only in July 2012, after trial; appellate review affirmed denial of his claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the delay between arrest and trial violated the Sixth Amendment	Brock asserts presumptive prejudice from eight-year delay.	State argues delay weighed against Brock; no prejudicial violation.	No constitutional violation; delay not prejudicial enough given circumstances.
Whether trial counsel was ineffective for not raising the speedy-trial issue earlier	Counsel failed to defend by timely asserting speedy-trial rights.	Strategic choice favored delaying; time benefited Brock; no deficient performance.	Counsel's performance not deficient; strategy reasonable; no ineffective-assistance.

Barker v. Wingo, 407 U.S. 514 (U.S. Supreme Court 1972) (framework for evaluating speedy-trial rights)
Doggett v. United States, 505 U.S. 647 (U.S. Supreme Court 1992) (prejudice considerations in delay analysis)
Ruffin v. State, 284 Ga. 52 (Ga. 2008) (delay attributable to State weighed lightly when not explained)
Washington v. State, 243 Ga. 329 (Ga. 1979) (speedy-trial interests include pretrial imprisonment, anxiety, defense impairment)
Wilkie v. State, 290 Ga. 450 (Ga. 2012) (extended delay normally weighed against defendant)
Hampton v. State, 272 Ga. 284 (Ga. 2000) (credibility resolutions reserved to jury)
Sweatman v. State, 287 Ga. 872 (Ga. 2010) (delay attributed to State weighed lightly when cause unclear)
Caldwell v. State, 263 Ga. 560 (Ga. 1993) (jury credibility determinations are for the jury)
Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (standard for reviewing sufficiency of evidence)
Bark er v. Wingo, 407 U.S. 514 (U.S. Supreme Court 1972) (see Barker v. Wingo (duplicate entry kept for completeness))