Matthew Blake Courtney v. State of Mississippi, 275 So. 3d 1032

In Nov. 2012 a 15‑year‑old victim was intoxicated at a party; medical examiners found injuries and DNA evidence linking multiple partygoers; youth‑court petition filed May 2, 2014 alleging sexual battery by then‑17‑year‑old Courtney.
Youth court transferred the matter to circuit court June 30, 2015; arrest warrant issued July 8, 2015; grand jury indicted Sept. 18, 2015.
Multiple continuances occurred pretrial; Courtney waived arraignment April 7, 2016, was appointed counsel, moved repeatedly for continuances, requested discovery (including a speedy‑trial demand) in May 2016, but joined several agreed continuances thereafter.
Trial occurred Aug. 15, 2017; jury convicted Courtney of sexual battery and the trial court sentenced him to 25 years.
On appeal Courtney argued (1) the two‑year statute of limitations barred prosecution and (2) his Sixth Amendment right to a speedy trial was violated due to delay beginning with the youth‑court petition.
The Court held Courtney waived the statute‑of‑limitations defense by not raising it in circuit court and applied Barker balancing to reject the speedy‑trial claim, affirming conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the prosecution was barred by the 2‑year statute of limitations	State: youth‑court petition (May 2, 2014) tolled/served as charging event so prosecution timely	Courtney: arrest July 8, 2015 was >2 years after Nov. 2, 2012; statute had run	Waived by Courtney at trial; not addressed on merits — defense forfeited
When the Sixth Amendment speedy‑trial clock began	State: constitutional clock begins at arrest/indictment (post‑youth court)	Courtney (and dissent): clock began when youth‑court petition filed May 2, 2014	Majority: constitutional right attached at arrest/indictment (July 8, 2015) — youth court petition does not start clock
Whether Barker factors show constitutional speedy‑trial violation	Courtney: lengthy delay and youth‑court delay prejudiced him	State: much of delay was defendant‑caused or by agreed continuances; no prejudice shown	Majority: delay presumptively prejudicial by length, but remaining Barker factors weigh against Courtney; no violation
Remedy if violation found	Courtney: dismissal warranted if rights violated	State: n/a	No speedy‑trial violation found; conviction affirmed

Barker v. Wingo, 407 U.S. 514 (Barker balancing test for speedy‑trial claims)
United States v. Marion, 404 U.S. 307 (rule that indictment/arrest triggers constitutional speedy‑trial right)
Breed v. Jones, 421 U.S. 519 (juvenile proceedings and double jeopardy; discussed re: applicability of criminal protections)
In re Gault, 387 U.S. 1 (due process rights in juvenile proceedings; discussed re: juvenile protections)
McKeiver v. Pennsylvania, 403 U.S. 528 (Supreme Court reluctance to rigidly classify juvenile proceedings as criminal or civil)
Beavers v. State, 498 So.2d 788 (Mississippi precedent on attachment of speedy‑trial right when accused)
DeLoach v. State, 722 So.2d 512 (State bears burden to prove good cause for delay)
Bateman v. State, 125 So.3d 616 (application of Barker factors in Mississippi)