Nathaniel Castellanos v. State
2016 WY 11
| Wyo. | 2016Background
- Castellanos was arrested for two murders and an attempted murder from shootings in his home (Aug 23, 2011); tried Feb 18, 2014; convicted and sentenced to three consecutive LWOP terms.
- Multiple continuances and three defense teams: initial trial date March 20, 2012; ultimately tried Feb 2014 (869 days after arraignment, 927 days after arrest).
- Key delays arose from defense continuances, the State’s death-penalty election timeline, competency evaluations (two evaluations, suspension of proceedings), and logistical docket scheduling.
- Castellanos repeatedly asserted his speedy-trial right and objected to continuances; court repeatedly found continuances warranted for due administration of justice and that defendant would not be substantially prejudiced.
- Post-conviction claims on appeal: (1) violation of W.R.Cr.P. 48 and Sixth Amendment speedy-trial rights; (2) ineffective assistance by first-appointed counsel; (3) erroneous denial of challenges for cause of two jurors.
- Court affirmed: no Rule 48 or Sixth Amendment violation; ineffective-assistance claim rejected for lack of prejudice; jury-selection claim rejected for lack of demonstrated prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Speedy trial (W.R.Cr.P. 48) | Delay exceeded 180 days; many continuances attributable to Public Defender assignment/systemic failure -> state responsibility | Most delays excluded under Rule 48 (mental-competency proceedings, valid continuances for due administration of justice) | No Rule 48 violation; excluded delays and court continuances lawful |
| Sixth Amendment speedy trial | 927-day delay presumptively prejudicial; majority of delay charged to State | Majority of delay attributable to defense (continuances, competency issues neutral); defendant asserted right; no impairment of defense | No constitutional violation after Barker balancing; delays largely defense-attributable and not substantially prejudicial |
| Ineffective assistance (Defense Team One) | Appointed attorneys lacked capital experience, were unprepared at hearings, failed to submit mitigation letter, poor performance led to delay and lost/stale evidence | Any performance issues did not prejudice outcome; defendant offers no specific lost-evidence or outcome-impact proof | Denied: court assumed possible performance issues but rejected claim for lack of demonstrated prejudice |
| Jury selection / challenges for cause | Court erred denying challenges for cause to two jurors, forcing use of peremptories on them and leaving jurors defendant would have struck | Denial was within court’s discretion; defendant failed to show prejudice from jurors who served | Denied: no abuse of discretion or harmful prejudice shown (peremptory cures and jurors were impartial) |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (four-factor balancing test for Sixth Amendment speedy-trial claims)
- Potter v. State, 158 P.3d 656 (Wyo. 2007) (competency proceedings toll Rule 48 speedy-trial clock until court’s final competency determination)
- Rodgers v. State, 265 P.3d 235 (Wyo. 2011) (practical impossibility of holding trial immediately after suspension supports reasonable continuance)
- Detheridge v. State, 963 P.2d 233 (Wyo. 1998) (court and prosecution must act to comply with Rule 48 after defendant’s speedy-trial demand)
- Klahn v. State, 96 P.3d 472 (Wyo. 2004) (use of peremptory to cure denial of challenge for cause is not reversible absent demonstration of prejudice)
- Durkee v. State, 357 P.3d 1106 (Wyo. 2015) (allocation of delay among State, defendant, neutral causes; application of Barker factors)
- Miller v. State, 217 P.3d 793 (Wyo. 2009) (competency-evaluation delays treated as neutral in speedy-trial analysis)