State of Iowa v. Christopher Clay McNeal, 15-1606

State charged McNeal with multiple counts (including attempt to commit murder, first-degree burglary, willful injury, and assaults) via information filed March 30, 2015; McNeal demanded a speedy trial under Iowa R. Crim. P. 2.33(2)(b).
Trial initially set for June 9; McNeal rejected a plea on June 9 and confirmed he would not waive his speedy-trial right; the court continued trial to June 23.
On June 16 the State disclosed additional medical witnesses and said three medical experts needed to prove serious injury were unavailable for the June 23 date; the State proposed picking a jury within the 90-day window and postponing evidentiary presentation until experts could be scheduled.
The district court approved empaneling the jury (jury selection completed June 26) but recessed the trial and resumed with opening statements and evidence on July 7 — nine days after the 90-day deadline (which expired June 28).
The jury convicted McNeal of willful injury causing serious injury and criminal trespass; on appeal the court considered whether the State satisfied the speedy-trial rule and whether it showed good cause for the delay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preservation of speedy-trial claim	State: McNeal acquiesced by not objecting after jury selection	McNeal: preserved by objection at pretrial and June 16 ruling; no need to renew objection	Preserved — district court made a final ruling on June 16, so further objection not required
Whether jury selection within 90 days "brought to trial"	State: empaneling jury within 90 days tolls the rule, permitting short recess before evidence	McNeal: empaneling then adjourning is a start-and-stop ruse that fails to satisfy "brought to trial"	Empaneling followed by an 11-day recess did not constitute being "brought to trial" under rule 2.33(2)(b)
Whether the State showed "good cause" for delay past 90 days	State: delay justified because critical medical witnesses were unavailable	McNeal: State failed to substantiate unavailability; delay due to State’s failure to subpoena and schedule after plea fell through	No — State’s general, unsupported assertions did not meet burden to show good cause
Remedy for rule violation	State: convictions should stand because procedural defect was slight	McNeal: dismissal required for violation of 90-day rule	Convictions reversed and case remanded for dismissal of the trial information

State v. Orte, 541 N.W.2d 895 (Iowa 1995) (standard of review for speedy-trial legal error)
State v. Winters, 690 N.W.2d 903 (Iowa 2005) (prosecutor must show good cause; bare assertions insufficient)
State v. Taylor, 881 N.W.2d 72 (Iowa 2016) (explains good-cause test focuses on reason for delay)
State v. Jones, 281 N.W.2d 13 (Iowa 1979) (noting jury impanelment and swearing generally marks trial commencement)
State v. Petersen, 288 N.W.2d 332 (Iowa 1980) (contextual factors relevant to good-cause analysis)
State v. Hines, 225 N.W.2d 156 (Iowa 1975) (short exceedances of statutory deadlines are not automatically excusable)
State v. Miller, 637 N.W.2d 201 (Iowa 2001) (strict construction of speedy-trial rule; small violations not excused)
Ennenga v. State, 812 N.W.2d 696 (Iowa 2012) (policy purposes of speedy-trial rule)
United States v. Brown, 819 F.3d 800 (6th Cir. 2016) (federal courts condemn start-and-stop voir dire to evade speedy-trial requirements)
United States v. Scaife, 749 F.2d 338 (6th Cir. 1984) (vacating conviction where voir dire within limit was followed by prolonged recess)
United States v. Crane, 776 F.2d 600 (6th Cir. 1985) (similar criticism of start-and-stop procedures)
United States v. Gonzalez, 671 F.2d 441 (11th Cir. 1982) (warning against using empanelment as device to evade speedy-trial statutes)
Rhinehart v. Municipal Court, 677 P.2d 1206 (Cal. 1984) (empaneling jury on last statutory day then delaying trial held a device to avoid speedy-trial rule)