State of Iowa v. Chad Steven Lester, 15-1444

Background

Chad Lester was charged with OWI (first offense) via trial information filed November 4, 2014, and filed a written arraignment demanding a speedy trial the same day.
The district court set pretrial and trial dates; on January 6, 2015, the court (according to its bench statement) scheduled final pretrial and trial dates (March 27 and April 23, 2015) with Lester and counsel present.
Lester filed a motion to suppress (Jan 14, 2015); the motion was heard Feb 10 and denied Feb 13, 2015. Trial remained scheduled for April 23, 2015 (170 days after charging).
On April 13, 2015 Lester moved to dismiss for violation of the 90-day speedy-trial rule; the State argued delay was justified by Lester’s failure to obtain a court-ordered substance-abuse evaluation and by the pending suppression motion, and that Lester had waived the rule by agreeing to the late trial date.
The district court denied the motion to dismiss, finding waiver/good cause based on Lester’s alleged agreement to the April 23 date; the case proceeded to trial (bench) June 18, 2015, where Lester was found guilty.
The court of appeals reversed, holding the State failed to prove waiver, defendant-caused delay, or sufficient good cause to exceed the 90-day rule, and remanded with instruction to dismiss the information.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 90-day speedy-trial rule was violated	State: Delay excused because Lester failed to obtain court-ordered substance-abuse evaluation and filed a suppression motion; plus Lester agreed to the later trial date	Lester: He demanded speedy trial; he did not intentionally waive it; his conduct did not actively cause delay	Held: Violation — State failed to prove waiver, defendant-caused delay, or good cause for the full delay; conviction reversed and information dismissed
Whether Lester waived speedy-trial rights by agreeing to the April 23 trial date	State: Lester and counsel were present and agreed to the trial date beyond the 90-day period, constituting waiver	Lester: Mere acquiescence to a later date is not waiver absent additional circumstances showing intentional relinquishment	Held: No waiver — mere agreement/acquiescence insufficient without additional active participation showing intent to abandon the right
Whether the pending motion to suppress justified the April 23 trial date	State: Suppression motion pending near the deadline justified moving trial beyond 90 days	Lester: Motion filed 19 days before deadline; court ruled on it Feb 13 — long before April 23 — so it did not justify the remaining delay	Held: Even assuming the suppression motion justified some delay, it did not justify the additional time up to April 23; State did not show good cause for remaining delay
Whether failure to obtain court-ordered substance-abuse evaluation justified delay	State: Lester’s noncompliance warranted continued delay	Lester: He ultimately proceeded to trial without the evaluation; noncompliance did not actively cause the lengthy delay	Held: Failure to obtain the evaluation did not constitute sufficient additional circumstance to support waiver or good cause

Key Cases Cited

State v. Winters, 690 N.W.2d 903 (Iowa 2005) (sets framework for 90-day rule exceptions)
State v. Hines, 225 N.W.2d 156 (Iowa 1975) (State must show good cause; dismissal required absent exceptional circumstances)
State v. Miller, 637 N.W.2d 201 (Iowa 2001) (burden on State to prove exception; suppression motions can justify limited continuances)
State v. Phelps, 379 N.W.2d 384 (Iowa Ct. App. 1985) (mere acquiescence in setting a trial date is not dispositive of waiver)
State v. Zaehringer, 306 N.W.2d 792 (Iowa 1981) (waiver requires additional active participation demonstrating abandonment of speedy-trial right)
Johnson v. Zerbst, 304 U.S. 458 (U.S. 1938) (waiver requires intentional relinquishment or abandonment of a known right)