Raphiel Pier Quinnie v. State of Alabama, 382 So.3d 1275

Quinnie was arrested July 12, 2016; he was later indicted (April 2017) for unlawful possession of a short-barreled shotgun while also indicted for murder (May 2016).
Quinnie was tried, convicted (January 2018), and sentenced to life for murder on March 1, 2018; at sentencing the State asked — without objection — that the shotgun charge be placed on the circuit court’s administrative docket pending appeal of the murder conviction.
The murder conviction was affirmed and certiorari denied (April–July 2019); the shotgun charge remained on the administrative docket until May 2021 when the court set a status conference.
Quinnie moved to dismiss the shotgun charge for a speedy-trial violation on August 24, 2021; the circuit court denied the motion after a hearing applying Barker v. Wingo.
On February 8, 2022, Quinnie pleaded guilty to unlawful possession of a short-barreled shotgun while reserving the right to appeal the denial of the speedy-trial motion; he was sentenced to two years’ imprisonment.
On appeal the Court of Criminal Appeals reviewed the Barker factors de novo and affirmed the denial of Quinnie’s motion to dismiss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether delay length triggers Barker	Delay from arrest (July 12, 2016) to plea (Feb 8, 2022) ≈ 67 months; this triggers Barker	State conceded the delay triggered Barker	67‑month delay measured from arrest to plea triggers Barker and weighs against the State
Proper attribution of reasons for delay	Portions were deliberate and negligent; State’s admin‑docket request was deliberate	State: delay partly justified by concurrent murder prosecution and later by administrative docket and COVID suspension	No deliberate delay; ~41 months attributable to negligent State delay (murder‑prosecution period and 6 months of COVID suspension excluded or neutral)
Whether defendant timely asserted right	Quinnie first asserted right Aug 24, 2021 and urged neutrality of that factor	State: Quinnie acquiesced for years and thus failed to assert promptly	Because Quinnie waited >3 years after the murder trial (and >5 years from arrest) to assert, the assertion factor weighs heavily against him
Whether prejudice is presumed or shown	Quinnie sought presumed prejudice from negligence and claimed collateral harms (program ineligibility, parole/good‑time effects)	State: delay <5 years for presumption; defendant must show actual prejudice and did not do so on appeal	No presumption of prejudice (delay <5 years); Quinnie did not demonstrate actual prejudice on appeal; factor weighs against Quinnie

Barker v. Wingo, 407 U.S. 514 (establishes four‑factor speedy‑trial test)
Doggett v. United States, 505 U.S. 647 (presumptive prejudice concept and threshold for triggering Barker inquiry)
Ex parte Walker, 928 So. 2d 259 (Ala. 2005) (Alabama guidance on balancing Barker factors)
Wilson v. State, 329 So. 3d 71 (Ala. Crim. App. 2020) (measuring delay to plea and treating negligent delay weight)
Roberson v. State, 864 So. 2d 379 (Ala. Crim. App. 2002) (delay measured from arrest or indictment)
State v. Jones, 35 So. 3d 644 (Ala. Crim. App. 2009) (discussion of when courts presume prejudice for lengthy negligent delay)
State v. Ramirez, 184 So. 3d 1053 (Ala. Crim. App. 2014) (administrative‑docket delay characterized as negligent)