Eagle v. State
2012 Ark. App. 187
Ark. Ct. App.2012Background
- Eagle was convicted of insurance fraud and attempted theft by jury.
- Eagle challenged the denial of his motion to dismiss for lack of a speedy trial.
- Arkansas Supreme Court rule: speedy-trial dismissal if not tried within 12 months; burden shifts to State to justify delays.
- Arrested Feb 7, 2008; tried Feb 24, 2011; trial fell 748 days beyond 365-day limit.
- Court found State failed to prove exclusions or justifications; calculation error by trial court.
- Result: conviction reversed and case dismissed with a bar to retrial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the speedy-trial clock was properly calculated | Eagle: several periods were not excludable | State: some periods properly excludable | Portions not properly excluded; total exceeds 365 days; dismissal required |
| Whether delays after competency exam were attributable to Eagle | Delay was not Eagle's fault; State must prove defendant-caused delay | Delay partly attributable to defendant or not justified | Most post-exam delays counted against State; only certain excluded periods recognized; overall still excessive |
| Whether the eight-day delay from Feb 16–24, 2011 was excludable | Eight days should be counted against State | Delay due to witness unavailability; excludable | Eight-day period excludable under Rule 28.3(d)(1) as witness unavailability |
Key Cases Cited
- Burmingham v. State, 346 Ark. 78 (2001) (speedy-trial rule framework and exclusion standards)
- Romes v. State, 356 Ark. 26 (2004) (time-period exclusion when exam ordered and report filed)
- Camargo v. State, 346 Ark. 118 (2001) (competency evaluation exclusion guidance)
- Miller v. State, 100 Ark.App. 391 (2007) (pretrial motions do not toll unless delay actually results)