Sharon Denise Jackson v. State, 05-14-00283-CR

Sharon Denise Jackson was arrested for possession of cocaine on December 19, 2011; she was released after three days.
The State did not present her case to the grand jury until May 6, 2013; indictment returned May 30, 2013 (≈17 months after arrest).
Jackson filed a motion to dismiss for violation of her Sixth Amendment speedy-trial right on June 18, 2013; the trial court denied the motion after a November 1, 2013 hearing.
At the hearing Jackson testified a third party (Jose Rodriguez) placed the drugs in her purse and later said he was returning to Mexico; she claimed inability to locate him and some employment and emotional impacts from delay.
The State introduced lab results (represented at hearing as dated January 11, 2013) and explained its practice of waiting for lab results before seeking indictment; the record lacked explanation for the lab delay.
Jackson later entered a judicial confession and pleaded guilty on January 10, 2014; she appealed the denial of her speedy-trial dismissal motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the >1-year delay between arrest and indictment violated the right to a speedy trial	Jackson argued delay was presumptively prejudicial and warranted dismissal	State argued delay was justified by waiting for lab results and no deliberate tactical delay	Court: Delay was presumptively prejudicial but, balancing Barker factors, denial of dismissal affirmed
Weight of State's reason for delay	N/A (challenge to delay generally)	State: lab report issued Jan 11, 2013; policy to await lab results before indictment	Held: Lab delay did not justify the long pre-indictment delay; reason weighed slightly against State
Whether Jackson asserted/pressed her speedy-trial right during pre-indictment period	Jackson filed motion to dismiss ~6 weeks after indictment (June 2013) and argued she asserted rights promptly after indictment	State noted Jackson made no efforts to move case into court during ~18 months after arrest	Held: Jackson’s lengthy pre-indictment silence and lack of diligence weigh against her claim
Whether Jackson suffered actual prejudice from the delay	Jackson claimed witness (Rodriguez) became unavailable and asserted anxiety/employment harms	State noted lack of evidence of actual prejudice; Rodriguez’s unavailability was speculative	Held: No showing of actual prejudice; factor weighs for State

Barker v. Wingo, 407 U.S. 514 (1972) (four-factor balancing test for speedy-trial claims)
Doggett v. United States, 505 U.S. 647 (1992) (presumptively prejudicial delay standard)
Cantu v. State, 253 S.W.3d 273 (Tex. Crim. App. 2008) (defendant’s burden to show assertion and prejudice; pre-indictment silence weighs against defendant)
Gonzales v. State, 435 S.W.3d 801 (Tex. Crim. App. 2014) (application of Barker factors)
Munoz v. State, 991 S.W.2d 818 (Tex. Crim. App. 1999) (weighing conduct of prosecutor and defendant)
Shaw v. State, 117 S.W.3d 883 (Tex. Crim. App. 2003) (pre-indictment inaction undermines speedy-trial claim)
Santibanez v. State, 717 S.W.2d 326 (Tex. Crim. App. 1986) (backlog or staffing shortages do not automatically justify long delays)
Dillingham v. United States, 423 U.S. 64 (1975) (speedy-trial invocation need not await formal charge)
Dickey v. Florida, 398 U.S. 30 (1970) (different weights for reasons for delay)