Israel Saenz Vasquez v. State, 11-15-00038-CR

Appellant Israel Saenz Vasquez was indicted in June 2012 for felony DWI (subsequent offense) with two habitual-offender enhancements; bond posted and later revoked after bond violations.
Trial was set for September 2012 but did not occur; Appellant was arrested on a capias in June 2013 and remained incarcerated at times before trial.
Appellant filed a pro se motion for speedy trial in October 2014 and a motion to set aside the indictment in January 2015; the latter was denied and trial proceeded January 2015.
At trial Appellant stipulated to two prior DWI convictions for jurisdictional purposes but not expressly to the enhancement priors; the State presented fingerprint evidence of prior judgments.
The trial court assessed punishment at 35 years’ confinement (above the normal 2–10 year range for a third-degree felony), and the judgment originally left the enhancement finding blank.
On appeal Appellant raised (1) a Sixth Amendment speedy-trial claim and (2) that the sentence was illegal because the court did not expressly find the enhancement paragraphs “true.” The court modified the judgment to reflect an implicit finding that the enhancements were true and affirmed.

Issue	Appellant's Argument	State's Argument	Held
Whether Appellant's Sixth Amendment right to a speedy trial was violated by ~2 years, 7 months delay	Delay was presumptively unreasonable and prejudicial; trial came only after long incarceration	Delay lacked State explanation but Appellant delayed asserting right until Oct 2014; no shown prejudice to defense	No violation: length and State’s lack of explanation favor Appellant, but late assertion and lack of demonstrated prejudice weigh against; Barker factors balanced against relief
Whether the sentence was illegal because trial court did not make an express “true” finding on habitual-offender enhancements	Sentence exceeded statutory range for a 3rd-degree felony absent enhancement; lack of express finding renders sentence unauthorized	Trial court implicitly found enhancements true (punishment within enhanced range; State proved priors)	No error: sufficient evidence and sentencing reflect an implicit finding of “true”; appellate court modified judgment to record that finding

Barker v. Wingo, 407 U.S. 514 (establishing four-factor speedy-trial balancing test)
Doggett v. United States, 505 U.S. 647 (delay approaching one year triggers Barker inquiry)
Gonzales v. State, 435 S.W.3d 801 (speedy-trial right applies at time of charge/arrest)
Cantu v. State, 253 S.W.3d 273 (standard of review and speedy-trial analysis under Texas law)
Roberson v. State, 420 S.W.3d 832 (State bears burden to prove habitual-offender allegations)
Reed v. State, 500 S.W.2d 497 (trial court need not obtain plea of “true”/“not true” when assessing punishment)
Torres v. State, 391 S.W.3d 179 (recognizing implicit findings of enhancement when record supports truth of allegations)