374 P.3d 1244
Wyo.2016Background
- Lafferty was first arrested and charged on Nov. 2, 2012; he remained incarcerated and the constitutional speedy-trial clock ran from that arrest.
- Initial charge (Docket 31-585) was dismissed July 31, 2013; State filed a separate multi-count information (Docket 31-757) and later refiled the original charge (Docket 31-819); the periods of formal charging were tacked together for speedy-trial purposes.
- Multiple continuances, three changes of public defenders, repeated vacated trial dates for prospective plea hearings, and two competency evaluations (one at State Hospital and a private second evaluation) significantly extended the pretrial timeline.
- The district court found the total delay from arrest to plea was 811 days and denied Lafferty’s motion to dismiss under the Barker speedy-trial test, concluding much of the delay was attributable to Lafferty and his counsel and that he failed to prove prejudice.
- Lafferty entered a conditional guilty plea (preserving the speedy-trial appeal) on Jan. 23, 2015; the Wyoming Supreme Court reviewed the claim de novo and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lafferty was denied his Sixth Amendment right to a speedy trial by 811 days of pretrial delay | Lafferty: 811‑day delay was presumptively prejudicial and, given the totality of circumstances, violated his speedy‑trial right | State: Delay was largely caused by Lafferty (plea vacillations, continuances, competency evaluations, counsel changes); State did not deliberately delay; Lafferty failed to show actual prejudice | Court: Affirmed denial of dismissal — delay presumptive but Barker factors weighed against Lafferty (most delay attributable to him; assertions of right minimal in vigor; no proven prejudice) |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (establishes four‑factor speedy‑trial balancing test)
- Rhodes v. State, 348 P.3d 404 (Wyo. 2015) (speedy‑trial standards and de novo appellate review)
- Ortiz v. State, 326 P.3d 883 (Wyo. 2014) (discusses when speedy‑trial clock is tolled for dismissed and refiled charges)
- Humphrey v. State, 185 P.3d 1236 (Wyo. 2008) (tacking of formal charging periods by single sovereign)
- Castellanos v. State, 366 P.3d 1279 (Wyo. 2016) (delay length and prejudice analysis under Barker)