People v. Wiggins
39 N.Y.S.3d 395
| N.Y. App. Div. | 2016Background
- In May 2008 defendant and co-defendant Jamal Armstead were implicated in a shooting outside a party; a 15‑year‑old bystander was killed. Defendant was arrested May 28, 2008.
- Both were indicted July 2008 on murder, attempted murder and weapon charges; defendant moved (Aug 2008) for severance and raised Bruton/confrontation concerns.
- Extensive adjournments followed (2009–2014) for reasons including plea negotiations with Armstead, multiple Huntley hearings, counsel substitutions, courthouse disruptions (fire, Hurricane Sandy), and several mistrials in multiple Armstead trials.
- Defendant remained detained throughout; he incurred separate indictments and later a conviction for an unrelated Rikers assault (sentence ~4.5 years).
- After more than six years of pretrial delay, defendant pleaded guilty to first‑degree manslaughter (Sept 23, 2014) pursuant to a 12‑year term; the court modified statutory surcharge and victim assistance fees to conform to pre‑enactment rates.
- On appeal defendant challenged denial of his speedy‑trial motion; the majority evaluated the Taranovich factors and affirmed denial of dismissal and the sentence (except fee modifications).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pretrial delay violated speedy‑trial rights | People: delay largely attributable to legitimate prosecutorial efforts (securing co‑defendant’s cooperation), neutral events, and some defense‑requested adjournments; delays were in good faith | Defendant: six‑plus year delay (arrest to plea) was extraordinary, largely due to People’s repeated tactics to obtain/test co‑defendant’s cooperation and to try him first; prejudice (incarceration, lost rehabilitation, coerced plea) | Court: applied Taranovich factors, found reasons for delay justified, no showing of actual impairment; denied dismissal |
| Charge severity as justification for delay | People: homicide charges justify more deliberation and efforts to build the strongest case | Defendant: seriousness does not excuse unreasonable multi‑year delay | Held: nature of charge favors People; serious homicide increases prosecutorial caution |
| Attribution of specific adjournments | People: many adjournments were requested by/consented to by co‑defendant or defense and are not charged to the People | Defendant: majority of adjournments flowed from People’s strategy; severance delay (4 years) shows prejudice | Held: court credited many adjournments to neutral/defense reasons and prosecutorial good faith; found delays not penalizable |
| Prejudice from delay (defense impairment / incarceration/rehabilitation) | People: defendant failed to show specific, substantial prejudice to ability to defend; time in custody on other matters not chargeable here | Defendant: lengthy custody during formative years produced presumption of prejudice, impaired rehabilitation and coerced plea | Held: no demonstrable impairment proved; general prejudice or rehabilitation concerns insufficient to require dismissal under facts presented |
Key Cases Cited
- People v Taranovich, 37 N.Y.2d 442 (1975) (establishes five‑factor speedy‑trial balancing test)
- People v Singer, 44 N.Y.2d 241 (1978) (burden on prosecution to show good cause for protracted delay)
- People v Staley, 41 N.Y.2d 789 (1977) (recognizes certain multi‑year delays as extraordinary)
- Barker v. Wingo, 407 U.S. 514 (1972) (federal speedy‑trial balancing factors and treatment of reasons for delay)
- People v Kelly, 38 N.Y.2d 633 (1976) (unavailable/essential witness testimony can justify delay)
- People v Decker, 13 N.Y.3d 12 (2009) (prosecutorial discretion in case management is broad when exercised in good faith)
- Doggett v. United States, 505 U.S. 647 (1992) (lengthy delay can create presumptive prejudice; importance increases with delay)
- People v Sanders, 25 N.Y.3d 337 (2015) (standards for valid appellate‑waiver of rights)
- People v Lopez, 6 N.Y.3d 248 (2006) (appeal‑waiver principles)
- People v Romeo, 12 N.Y.3d 51 (2009) (requirements for showing prejudice from delay)
- People v Johnson, 38 N.Y.2d 271 (1975) (public interest and complexity considerations in speedy‑trial analysis)