Commonwealth v. Mills, L., Aplt., Commonwealth v. Mills, L., Aplt.

Appellant Leon Mills appealed a Superior Court decision reversing a trial court order related to Pa.R.Crim.P. 600 (speedy trial) calculations; the Supreme Court of Pennsylvania issued the opinion (Saylor, C.J.).
The opinion addresses how courts should allocate periods of delay between the Commonwealth and the judiciary when computing Rule 600 time, focusing on the concept of "judicial delay."
The Majority recognizes that periods of "judicial delay" can be excluded from Rule 600 computations, but emphasizes courts must first assess the Commonwealth’s due diligence.
The Commonwealth bears the burden to prove it exercised due diligence at all stages; only after such a showing may a court consider excluding time as "judicial delay."
The opinion discusses Commonwealth v. Bradford (46 A.3d 693) as an example where judicial delay was found only after the Commonwealth was shown to have exercised due diligence (despite anomalous facts).
The concurrence stresses that trial courts improperly treat "judicial delay" and the Commonwealth’s lack of due diligence as interchangeable; due diligence must be proven before invoking judicial delay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether periods of "judicial delay" may be excluded from Rule 600 computations without first assessing Commonwealth due diligence	Commonwealth: court calendar conflicts can justify exclusion as "judicial delay"	Mills: delays attributable to the prosecution (lack of due diligence) must be included	Court: Due diligence by the Commonwealth must be proven first; only then may delay be characterized as judicial and excluded
Burden of proof regarding due diligence under Rule 600	Commonwealth: burden may be flexible where court-caused delay appears	Mills: Commonwealth bears burden to prove due diligence for all stages	Court: Commonwealth bears the burden to demonstrate due diligence throughout; failure means delay is included in Rule 600 time
Proper order of inquiry under Rule 600(C)(1)	Commonwealth: courts can distinguish judicial vs. prosecutorial delay as needed	Mills: courts must first examine prosecutorial efforts before labeling delay judicial	Court: Linear reading requires first assessing Commonwealth due diligence, then considering judicial delay
Effect of Bradford precedent on judicial delay analysis	Commonwealth: Bradford allows recognizing judicial delay in some circumstances	Mills: Bradford does not excuse Commonwealth from showing due diligence	Court: Bradford remains instructive but judicial delay was recognized there only after finding Commonwealth due diligence; lower court misapplied this by treating categories as interchangeable

Commonwealth v. Bradford, 46 A.3d 693 (Pa. 2012) (recognizes judicial delay but only after finding Commonwealth exercised due diligence)
Commonwealth v. Browne, 584 A.2d 902 (Pa. 1990) (Commonwealth bears burden to prove due diligence)
Commonwealth v. Burno, 154 A.3d 764 (Pa. 2017) (due diligence requirement extends to all stages of prosecution)
Commonwealth v. Hawk, 597 A.2d 1141 (Pa. 1991) (due diligence obligation of the prosecution)
Commonwealth v. Smith, 383 A.2d 1280 (Pa. 1978) (prosecutors must take reasonable steps to try cases on time)