Johnson v. State
2011 Miss. LEXIS 335
| Miss. | 2011Background
- Johnson was convicted of aggravated assault in Hinds County Circuit Court; he moved for a speedy trial and bond reduction, but delays accumulated; arrest occurred February 2006, indictment February 2007, trial March 11, 2008; he remained jailed due to inability to post bond; the speedy-trial motion was heard on the day of trial; two prospective jurors were challenged for cause and ultimately excluded; the Court of Appeals affirmed, and the Mississippi Supreme Court granted certiorari to address speedy-trial and for-cause issues.
- The arrest-to-trial interval was 680 days, which the Court analyzed under Barker v. Wingo’s four factors: length of delay, reasons for delay, assertion of the right, and prejudice.
- The State’s asserted reason for delay was overcrowded dockets; Johnson asserted his right to a speedy trial and sought dismissal; Johnson did not demonstrate actual prejudice beyond incarceration, and the Court weighed prejudice against the State.
- The Court ultimately held the delay presumptively prejudicial but declined to find a violation of the speedy-trial right after applying Barker’s factors, and affirmed the trial court’s judgment.
- Johnson argued two trial jurors should have been excused for cause, but the Court held the trial court’s rulings did not prejudice Johnson since those jurors did not sit on the jury.
- The conviction for aggravated assault and 20-year sentence were affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Speedy-trial violation under Barker factors | Johnson | Johnson asserts 680-day delay violated speedy-trial rights | Delay presumptively prejudicial; State bears burden to show lack of prejudice; court nonetheless affirms ruling (no speedy-trial violation) |
| For-cause challenges to jurors | Johnson | Trial court erred in denying for-cause challenges; prejudice must be shown | No reversible error; jurors seated were impartial; challenges exhausted; claim rejected |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (establishes four-factor speedy-trial analysis)
- Smith v. State, 550 So.2d 406 (Miss. 1989) (eight-month presumptive prejudice threshold; Barker framework applied in Mississippi)
- Ferguson v. State, 576 So.2d 1252 (Miss. 1991) (presumption of prejudice shifts burden to State on the prejudice prong)
- Moore v. Arizona, 414 U.S. 25 (U.S. 1973) (rejected requirement of affirmative prejudice showing to prove denial of speedy trial)
- Prince v. Alabama, 507 F.2d 693 (5th Cir. 1975) (predecessor framework shifting burden upon prima facie showing of denial of speedy-trial right)
- Jenkins v. State, 947 So.2d 270 (Miss. 2006) (Mississippi Barker analysis sequel; factors weighing context)
- Manix v. State, 895 So.2d 167 (Miss. 2005) (presumption of prejudice and Barker analysis discussion)
- Moffett v. State, 49 So.3d 1073 (Miss. 2010) (presumptively prejudicial delay; prejudice analysis)
- Flora v. State, 925 So.2d 797 (Miss. 2006) (overcrowded docket considerations weighed in Barker analysis)