Singleton v. State
317 Ga. App. 637
| Ga. Ct. App. | 2012Background
- Singleton was arrested for simple battery on April 7, 2007.
- State sought felony charges; indictment occurred on October 29, 2009 with multiple counts.
- Singleton was arraigned and released on bond; new defense motions followed in 2010.
- Singleton filed a plea in bar on March 22, 2010; trial court denied on November 4, 2011.
- Court used 19 months (indictment to plea) to assess Barker factors, omitting 55-month delay from arrest.
- Georgia appellate court vacates and remands to reassess Barker factors with correct 55-month delay.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 55-month delay is presumptively prejudicial | Singleton—delay presumptively prejudicial. | State—delay not fully considered; may be weighed. | Yes; presumptive prejudice established, Barker analysis required. |
| Whether trial court erred by using 19 months instead of 55 months for delay | Court miscalculated delay by using indictment-to-plea period. | State—original calculation appropriate? (concise framing). | Remand; correct length of delay must be used. |
| Whether the delay was uncommonly long and who caused it | Delay largely attributable to state; overcrowded docket weighs against State. | Delay due to both parties/benign factors; not clearly deliberate. | Remand for proper assessment with correct facts. |
| Whether Singleton asserted the right to a speedy trial in due course | Delay over four years with no timely assertion weighs against Singleton. | Government delay warrants consideration; assertion timing matters. | Factor weighed against Singleton; but remand may alter outcome with correct delay. |
| Whether the prejudice from delay supports a speedy-trial violation | Presumptive prejudice increases with length of delay. | No concrete evidence of impairment shown; relies on presumption. | Remand to determine prejudice under correct 55-month delay. |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (framework for balancing Barker factors in speedy-trial claims)
- Williams v. State, 277 Ga. 598 (2004) (presumption of prejudice from long delays informs Barker balancing)
- Brown v. State, 264 Ga. 803 (1994) (speedy-trial standards; initial Barker factor guidance)
- Ruffin v. State, 284 Ga. 52 (2008) (explains factors for blame for delay in Barker-Doggett analysis)
- Porter v. State, 288 Ga. 524 (2011) (limits deference when trial court misstates facts or law in Barker analysis)
- Goddard v. State, 315 Ga. App. 868 (2012) (remand when trial court relied on incorrect delay period)
- Scandrett v. State, 279 Ga. 632 (2005) (when speedy-trial right attaches and timing is relevant)