City of Aztec v. Sisneroz, A-1-CA-36389

Defendant Anthony J. Sisneroz was convicted after a bench trial in district court of DWI, driving on laned roadways, and open container under Aztec City Code § 24-21-1.
Case reached the district court by de novo appeal from a municipal-court conviction; Defendant appealed from the municipal conviction on March 3, 2016 and filed a demand for speedy trial on March 11, 2016.
Multiple continuances occurred: a jury trial was originally noticed for July 21, 2016, continued to September 1, 2016, later rescheduled to October 28, 2016, then converted to a bench trial and set for December 21, 2016.
Defendant argued his speedy-trial right was violated because the de novo appeal and subsequent delays resulted in roughly eight months of delay in the district court and over fifteen months since arrest.
Defendant offered only generalized prejudice (the case could have proceeded faster) and did not identify particularized prejudice (e.g., impaired defense, oppressive incarceration, increased anxiety).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Defendant’s Sixth Amendment/right to speedy trial (under Barker) was violated by delays in the de novo appeal and continuances	The City argued delays were not presumptively prejudicial and Defendant failed to show particularized prejudice; district court findings are entitled to deference	Sisneroz argued the de novo appeal and prosecutor continuances produced an over-eight-month delay in district court (over 15 months total) and that delay was unreasonable for a simple case	Court affirmed: delay did not meet the 12‑month presumptively prejudicial threshold for simple cases, Defendant failed to show particularized prejudice, and Barker factors did not weigh in his favor

Barker v. Wingo, 407 U.S. 514 (1972) (establishes four-factor balancing test for speedy-trial claims)
State v. Smith, 367 P.3d 420 (N.M. 2016) (adopts Barker framework and describes factors to weigh)
State v. Flores, 355 P.3d 81 (N.M. Ct. App. 2015) (explains de novo appeal timing and standard of review for speedy-trial claims)
State v. Garza, 212 P.3d 387 (N.M. 2009) (requires particularized prejudice unless length and reasons for delay heavily favor defendant)
State v. Serros, 366 P.3d 1121 (N.M. 2016) (identifies core interests protected by speedy-trial right)
State v. Spearman, 283 P.3d 272 (N.M. 2012) (discusses the dual role of delay as trigger and factor in speedy-trial analysis)