Michael Taylor v. State of Mississippi, 162 So. 3d 780

Michael Taylor shot Michelle Finney in January 2007; arrested later that day on unrelated charges after police found a jacket with a gun and narcotics; indictment for aggravated assault returned May 2007.
Taylor remained in custody on the aggravated-assault charge and was tried in December 2008; total delay from effective arrest for these charges to trial was ~550 days (≈18 months).
Trial court denied Taylor’s speedy-trial motion; jury convicted him of aggravated assault and sentenced to five years (three suspended).
On appeal, appointed counsel filed a Lindsey brief certifying she found no arguable issues; the State agreed; the Court conducted an independent review and requested supplemental briefing on two issues, including speedy-trial.
Majority applied Barker balancing, found delay presumptively prejudicial but no actual prejudice, and affirmed conviction; two separate dissents concluded Taylor’s Sixth Amendment right was violated.

Issue	Plaintiff's Argument (Taylor)	Defendant's Argument (State)	Held
Whether Taylor's Sixth Amendment right to a speedy trial was violated	Delay of ~18 months was presumptively prejudicial; trial judge ignored Barker; overcrowded-docket excuse insufficient; prejudice presumed	Delay due mainly to crowded docket (not deliberate); defendant delayed asserting right; no actual prejudice shown (no lost evidence/witness)	Majority: No violation — length triggers Barker but crowded docket weighs little against State, assertion neutral, and no actual prejudice so overall balance favors State; Dissent: Violation — all Barker factors weigh for defendant and trial judge acted dismissively
Whether Lindsey procedure was properly followed and whether appeal presents arguable issues	(implicit) Counsel certified no arguable issues but defendant entitled to independent appellate review	Counsel complied with Lindsey requirements; Court must independently review record	Held: Lindsey complied with; Court performed independent review, requested supplemental briefing, and found no reversible issues

Lindsey v. State, 939 So.2d 743 (Miss. 2005) (procedure when appellate counsel finds no arguable issues)
Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four-factor balancing test for speedy-trial claims)
Jenkins v. State, 947 So.2d 270 (Miss. 2006) (analysis of prejudice and reasons for delay)
Bateman v. State, 125 So.3d 616 (Miss. 2013) (defendant’s assertion of the right and timing considered in Barker analysis)
Johnson v. State, 68 So.3d 1239 (Miss. 2011) (delay exceeding eight months is presumptively prejudicial but actual prejudice required for reversal)
Manix v. State, 895 So.2d 167 (Miss. 2005) (long delay without proof of actual prejudice does not necessarily violate speedy-trial right)