State of Iowa v. Deantay Darelle Williams, 895 N.W.2d 856

Early morning, June 10, 2012: two minors reported sexual assaults; police entered a house, detained occupants, took five males (including Deantay Williams, then 17) into custody, read Miranda rights, questioned them, collected consensual or warrant-obtained DNA swabs, then released them the same day; no criminal complaint was filed then.
Months later, in October 2013 police obtained arrest warrants; defendants were arrested and brought before a magistrate for initial appearances.
On November 1, 2013 (510 days after the June 10 events) the county attorney filed a trial information charging sexual abuse in the second degree.
Williams, Washington, and Smith moved to dismiss under Iowa’s speedy-indictment rule (Iowa R. Crim. P. 2.33(2)(a)) because the information was filed more than 45 days after they had been taken into custody.
The district court denied dismissal; the court of appeals reversed relying on precedent that the speedy-indictment clock can begin when a defendant is first taken into custody; the Iowa Supreme Court granted further review and affirmed the district court.

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (State)	Held
When does the 45-day speedy-indictment period begin?	Clock began when defendants were taken into custody, interrogated and released on June 10, 2012.	Clock begins only when an arrest is completed in the manner authorized by law — specifically when the arrestee is taken before a magistrate for an initial appearance.	The rule is triggered by arrest only when the statutory arrest process is completed by taking the person before a magistrate for an initial appearance.
Whether to follow/overturn prior precedent (Schmitt/Wing) that measured the clock from custody/seizure	Precedent supports measuring from the moment of custody; defendants relied on those decisions.	The court should correct earlier erroneous precedent and interpret the rule to require completion of statutory arrest steps.	Court overruled the narrower reading from Schmitt/Wing to require the arrest be completed (initial appearance) before the speedy-indictment clock runs; vacated court of appeals and affirmed district court.

State v. Schmitt, 290 N.W.2d 24 (Iowa 1980) (earlier court held speedy-indictment clock began when person was taken into custody)
State v. Wing, 791 N.W.2d 243 (Iowa 2010) (applied a Fourth Amendment seizure standard to trigger the speedy-indictment period)
State v. Dennison, 571 N.W.2d 492 (Iowa 1997) (held de facto investigative detentions did not always trigger speedy-indictment rule)
State v. Davis, 525 N.W.2d 837 (Iowa 1994) (applied statutory arrest definitions to determine when speedy-indictment protections attach)
State v. Penn-Kennedy, 862 N.W.2d 384 (Iowa 2015) (surveyed post-Schmitt cases and discussed consequences of measuring the clock from arrest)