Interest of C.L., 2011 ND 102

Hinojosa was charged with delivery of methamphetamine within 1000 feet of North Dakota State University, a class AA felony.
The alleged offense occurred June 3, 2009, in an apartment building near university property, involving a male and female confidential informants.
On Oct 2, 2009, while imprisoned on another matter, Hinojosa filed a Uniform Detainers Act request for a speedy trial within 90 days.
The trial date was repeatedly continued starting December 2009, due in part to defense conflict-of-interest issues and a unavailable state witness.
Defense counsel withdrew shortly before trial; a new attorney was appointed and the court found good cause to delay trial for defense preparation.
Trial occurred April 20–21, 2010, the jury found Hinojosa guilty; the court later denied post-trial motions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Detainers Act: whether continuances violated 90-day deadline	State contends good cause supported delay; no violation under Detainers Act.	Hinojosa contends the 90-day limit was breached, prejudicing him.	No violation; trial delay supported by good cause and lack of prejudice.
Sufficiency of evidence to prove delivery within 1000 feet of university	State argues the aerial map and related testimony establish distance within 1000 feet.	Hinojosa argues the evidence fails to place the door of the apartment within 1000 feet.	Evidence sufficient to sustain conviction.

State v. Moe, 581 N.W.2d 468 (ND 1998) (detainers Act applies to jailed prisoners; allows continuances for good cause)
State v. Carlson, 258 N.W.2d 253 (ND 1977) (detainers Act and need for personal waiver where applicable)
State v. Olsen, 540 N.W.2d 149 (ND 1995) (trial continuances within court discretion for good cause)
State v. Kania, 341 N.W.2d 361 (ND 1983) (abuse of discretion standard for continuances)
State v. Foster, 560 N.W.2d 194 (ND 1997) (good cause for delay includes defense preparation and complex issues)
State v. Moore, 725 N.W.2d 910 (ND 2007) (lack of prejudice weakens assertion of violation)