Nelson Bido v. State of Rhode Island, 56 A.3d 104

Bido was arrested in New York in 1991 for Confessor's murder; gun found in Colon’s possession.
An eyewitness led police to Bido’s license plate; he fled to New York and avoided Rhode Island authorities.
Rhode Island indicted him in July 1992; he remained in New York until extradition began in 2005.
Trial occurred in May 2006, resulting in guilty verdicts on conspiracy and aiding/abetting murder.
Bido filed postconviction relief in 2009 raising several issues, but the court focused on ineffective assistance for not seeking speedy-trial dismissal.
Trial court found the delay primarily caused by Bido’s conduct; appellate court agreed and held no speedy-trial error.]

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the delay violated the speedy-trial right under Barker v. Wingo.	Bido argues a lengthy delay breached speedy-trial rights.	State contends delay largely caused by Bido; not reversible.	No merit; delay attributed to Bido, not the State.
Whether counsel’s failure to move for speedy-trial dismissal was ineffective assistance.	Bido asserts counsel’s strategy harmed defense.	Counsel acted reasonably; merit would be unlikely.	No defective performance; prejudice not shown.

Barker v. Wingo, 407 U.S. 514 (U.S. Supreme Court, 1972) (four-factor speedy-trial framework applied)
State v. Crocker, 767 A.2d 88 (R.I. 2001) (deliberate delay by defendant weighed against him)
Doggett v. United States, 505 U.S. 647 (U.S. Supreme Court, 1992) (delay attributed to defendant mitigates prejudice)
Brillon v. Brillon, 556 U.S. 81 (U.S. Supreme Court, 2009) (defendant’s delay can weigh against him; extradition context considered)
Crocker v. State, N/A (R.I. 2001) ( Rhode Island appellate analysis of delay and defendant’s conduct)
State v. Oliveira, 961 A.2d 299 (R.I. 2008) (speedy-trial rights recognized under Rhode Island Constitution)