Scott Logan v. State of Indiana
16 N.E.3d 953
Ind.2014Background
- Logan was charged July 31, 2009 with class C felony child molestation; arrest August 7, 2009; initial hearing August 11, 2009.
- His pre-trial schedule involved several continuances and congestion-based delays beginning in 2009–2010.
- Logan spent 2.8 years (1,029 days) incarcerated before trial; total delay from charging to trial was 1,291 days.
- Multiple congestion-based continuances were granted between 2010 and 2012, including a priority given to another defendant’s Rule 4(B) motion.
- Logan’s jury trial finally began February 11, 2013, after extensive continuances; he was convicted and sentenced to six years.
- The Indiana Court of Appeals affirmed; this Court granted transfer to consider Rule 4(C) and constitutional speedy-trial claims; the Court ultimately discharged Logan and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 4(C) discharge was proper given congestion-based delay | Logan argues congestion violated Rule 4(C) | State argues congestion was proper under Rule 4(C) | No clear error; delay upheld under congestion exception |
| Whether 1,291-day delay violated the U.S. and Indiana speedy-trial rights | Logan asserts violation of Barker factors; fond of release | State contends delays were justified by congestion and Rule 4(B) priority for Outman | Delay violated both federal and Indiana speedy-trial rights; Logan discharged and conviction vacated |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four-factor balancing test for speedy-trial claims)
- Austin v. State, 997 N.E.2d 1027 (Ind. 2013) (priority treatment under Rule 4; applies to 4(C) as well as 4(B))
- Bridwell v. State, 659 N.E.2d 552 (Ind. 1995) (congestion findings reviewed for clear error)
- Sweeney v. State, 704 N.E.2d 86 (Ind. 1998) (speedy-trial claims weighed against defendant's delays)
- Ballentine v. State, 480 N.E.2d 957 (Ind. 1985) (long delays deemed unusually long when incarcerated out of state)
- Clark v. State, 659 N.E.2d 548 (Ind. 1995) (congestion findings reviewed; presumption of validity)
- Vermillion v. State, 719 N.E.2d 1201 (Ind. 1999) (delay attributed largely to defendant when defense readiness considered)
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (presumption of prejudice not essential to all speedy-trial claims)
- Klopfer v. North Carolina, 386 U.S. 213 (U.S. 1967) (speedy-trial rights grounded in fundamental justice)