Rodriques Lamar Johnson v. State of Indiana
2017 Ind. App. LEXIS 355
| Ind. Ct. App. | 2017Background
- On May 21–22, 2012, Rodriques Johnson allegedly threw a brick through a house window, set papers on fire inside, was arrested at the scene, and charged the next day with arson (initially Class D; later amended to Class B) and criminal mischief (misdemeanor later dismissed).
- The case did not go to trial until September 27, 2016 — a 1,579‑day span between arrest and trial.
- Multiple continuances occurred: court congestion caused several calendar moves, and Johnson repeatedly sought competency/psychiatric evaluations and filed motions for continuance; his counsel also withdrew twice.
- The State objected to some last‑minute competency and continuance motions; the trial court denied the late motions and found Johnson competent.
- A jury convicted Johnson of arson and he was sentenced to ten years in the Indiana Department of Correction. Johnson appealed, arguing a speedy‑trial violation.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Johnson) | Held |
|---|---|---|---|
| Whether the 1,579‑day delay violated Johnson's Sixth Amendment/Indiana speedy‑trial right | Most delay attributable to defendant (competency exams, continuances, counsel changes); some delay due to court congestion; State did not purposely delay; no showing of prejudice | Delay was presumptively prejudicial, State acquiesced in many delays, Johnson suffered anxiety — constitutional right violated | Court affirmed conviction: Barker factors weigh against Johnson — delay triggered review but majority of delay was defendant‑caused, Johnson never timely asserted the right, and he showed no actual prejudice |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (sets four‑factor balancing test for speedy‑trial claims)
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (delay over one year is presumptively prejudicial and factors for extent of delay)
- Vermillion v. State, 719 N.E.2d 1201 (Ind. 1999) (one‑year threshold and presumption of prejudice discussed under Indiana law)
- Sweeney v. State, 704 N.E.2d 86 (Ind. 1998) (analysis equivalence of federal and state speedy‑trial claims and Barker application)