James Robert Rowsey v. State of Mississippi, 188 So. 3d 486

Background

In January 2010 James Rowsey, serving a life sentence for murder, poured scalding water on inmate Fate Santee, causing severe burns; Rowsey was indicted for aggravated assault in Feb. 2011 and tried Feb. 2014.
Numerous continuances occurred over ~36 months between indictment and trial: defense counsel changes, motions, delays obtaining a court-ordered mental evaluation, and an incident where jurors saw Rowsey in restraints prompted an additional continuance.
Rowsey repeatedly asserted speedy-trial claims in pro se filings and through counsel, but the trial court did not rule on those motions before trial.
At trial Rowsey testified, admitting the act and asserting self‑defense; the jury convicted him of aggravated assault and the court imposed a consecutive 10‑year sentence.
On appeal Rowsey (through counsel and pro se) raised constitutional and statutory speedy‑trial claims, ineffective assistance/conflict claims, coercion to testify, sanctioning for frivolous filings, and alleged omissions/misfiled documents in the record.
The Supreme Court of Mississippi affirmed, holding delay was justified by good cause (mainly defense‑requested mental evaluation and defense‑caused delay), overruling prior state authority to the extent it treated failure to obtain a trial‑court ruling as waiver of the constitutional speedy‑trial right, and rejecting Rowsey’s other claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutional speedy‑trial violation	Rowsey: 36‑month delay between indictment and trial violated his Sixth Amendment right	State: Delay largely due to defense actions (harassment of counsel, requests for mental evaluation) and other continuances; good cause exists	No violation — Barker factors weighed for State; delay attributable to defense and necessary mental exam; overrules cases holding failure to obtain ruling equals waiver
Statutory speedy‑trial (Miss. Code §99‑17‑1)	Rowsey: Trial exceeded 270 days after arraignment	State: Good cause and duly granted continuances (mental evaluation, defense continuances)	No violation — statutory clock tolled for good cause; mental evaluation justified continuances
Ineffective assistance / actual conflict of interest	Rowsey: counsel ineffective; counsel had conflict/animus and asked him to waive arraignment; appellate counsel raised only speedy‑trial issues	State: Record shows counsel performed investigations, motions, cross‑examination, and strategic choices; conflict was personality, not an actual conflict compromising loyalty	No relief — Strickland not met; no actual conflict under Kiker; representation not shown deficient or prejudicial
Coerced testimony, sanctions, and record completeness	Rowsey: was forced to testify; sanctions and clerk record errors denied rights	State: No record evidence of coercion; sanctionable pleading was frivolous/abusive; misfiled pages immaterial	No relief — no record support that counsel forced testimony; sanction was within court discretion; misfiled pages did not affect outcome

Key Cases Cited

Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (announces four‑factor balancing test for constitutional speedy‑trial claims)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part standard for ineffective assistance of counsel)
Kiker v. State, 55 So.3d 1060 (Miss. 2011) (actual conflict of interest by defense counsel is per se ineffective assistance)
Myers v. State, 145 So.3d 1143 (Miss. 2014) (discusses appellate handling/remand when trial court failed to resolve speedy‑trial claim)
Berry v. State, 728 So.2d 568 (Miss. 1999) (right to speedy trial subject to knowing/intelligent waiver; trial court error where motion to dismiss not ruled upon)
Kolberg v. State, 829 So.2d 29 (Miss. 2002) (prior state decision treating failure to obtain trial‑court ruling as waiver, partially overruled here)
Wells v. State, 160 So.3d 1136 (Miss. 2015) (similar to Kolberg; overruling narrowed where it treated lack of ruling as waiver)