Jonathan Edward Boyer v. Louisiana, 569 U.S. 238

Boyer and his brother hitchhiked in Calcasieu Parish, Louisiana; Boyer robbed and murdered a driver and fled to Florida.
Boyer was indicted in Louisiana for first-degree murder and the state sought the death penalty; defense funds were in dispute.
From 2002 to 2006, funding hearings and related delays dominated proceedings, with multiple continuances and Hurricane disruptions.
In 2005–2006, a funding hearing occurred; the state then ceased seeking the death penalty, reducing defense complexity and costs.
Lorenzi, the lead defense attorney, was replaced by LCAC attorneys paid by the State, shifting lead counsel; the case proceeded slowly.
Boyer was tried and convicted in 2009 after a seven-year delay, with the Louisiana appellate court holding most delay was caused by funding but not weighing it against the State.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a State's failure to fund indigent defense is weighed against the State in speedy-trial analysis	Boyer	Louisiana	Yes; such delay weighs against the State

Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (speedy-trial standard balancing four factors)
Vermont v. Brillon, 556 U.S. 81 (U.S. 2009) (state-system delays may be charged to the State)
Hernandez v. New York, 500 U.S. 352 (U.S. 1991) (plurality on attributing responsibility for delays)
United States v. Loud Hawk, 474 U.S. 302 (U.S. 1986) (weights of reasons for delay vary by context)