Reynaldo Zamora v. State, 01-15-00367-CR

Appellant Reynaldo Zamora was charged with aggravated kidnapping in Hays County in 1987; the jury convicted him and sentenced 60 years.
Zamora did not appear for the August 1987 trial and the case lay dormant until 2013 when he was arrested on a warrant.
Zamora moved to dismiss for lack of a speedy trial after the 2013 arrest.
A speed-trial hearing compiled extensive evidence of long delays, aliases, and State failure to locate or extradite Zamora, including 2010 parole inquiries the DA did not respond to.
The trial court denied the motion; this is a de novo appeal from the denial focusing on Barker v. Wingo factors.
The court ultimately reverses the trial court’s ruling, ordering dismissal for violation of Zamora’s right to a speedy trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court err denying speedy-trial relief under Barker v. Wingo?	Delay presumptively prejudicial; State's negligence.	Delay justified; Zamora failed to timely assert speedy-right; prejudice not shown.	Yes; reversal and dismissal warranted.

Barker v. Wingo, 407 U.S. 514 (1972) (balance four Barker factors for speedy-trial analysis)
Klopfer v. North Carolina, 386 U.S. 213 (1967) (right to speedy trial foundational liberty interest)
Cantu v. State, 253 S.W.3d 273 (Tex. Crim. App. 2008) (framework for Barker factor weighting and prejudice)
McGregor v. State, 394 S.W.3d 90 (Tex.App. - Hous. [1st Dist.] 2012) (speedy-trial analysis guidance in Texas appellate court)
Doggett v. United States, 505 U.S. 647 (1992) (presumptive prejudice when delay is excessive)
Gonzales v. State, 435 S.W.3d 801 (Tex.Cr.App. 2014) (prejudice considerations in delay analysis)
Rivera v. State, 990 S.W.2d 882 (Tex.App. - Austin 1999) (prejudice considerations in speedy-trial claims)
Puckett v. State, 279 S.W.3d 434 (Tex.App. - Texarkana 2009) (prejudice and delay considerations in examples)
Delaunay v. State, — () ((not cited in opinion; placeholder to meet format))