State of Iowa v. Deyawna Leanett Taylor, 2016 Iowa Sup. LEXIS 73

Background

Story County charged Deyawna Taylor (driving while barred; prostitution) on July 28, 2014; arraignment set for August 11 but Taylor was in Polk County jail on unrelated charges and failed to appear.
State filed transport motion on October 29; Taylor was arraigned November 12. Trial was set for December 16.
On November 12, the parties executed a proffer agreement under which Taylor would cooperate (testify in another defendant’s trial) and later receive reduced charges; transcript of that proffer was not introduced at the dismissal hearing.
The 90-day speedy-trial deadline under Iowa Rule 2.33(2) expired October 27; Taylor moved to dismiss for violation on December 8.
At the December 10 hearing the State argued (1) Taylor waived speedy trial by agreeing to the November 12 proffer and (2) incarceration in Polk County furnished good cause; the district court found waiver, convicted Taylor, and imposed sentence. The Iowa Supreme Court reversed and remanded for dismissal.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Taylor)	Held
Whether the State proved "good cause" to excuse trial delay due to Taylor's incarceration in another county	Polk County custody prevented appearance; State only learned of her custody on Oct 29 so delay was excusable	State had responsibility to locate detainees; no evidence of State diligence or of communication breakdown	No — State failed to show due diligence or specific facts; incarceration alone did not establish good cause
Whether Taylor waived speedy-trial rights by signing the November 12 proffer agreement	The proffer showed Taylor agreed to delay (would testify later; cases would take months) and thus impliedly waived speedy trial	Proffer occurred after the 90-day deadline; waiver must be knowing, intentional, and on the record — State offered no evidence that Taylor knowingly waived speedy trial	No — State did not meet burden to show a knowing, intelligent waiver; mere acquiescence insufficient
Whether plea-bargain/proffer negotiations can support waiver or good cause when they span the deadline	Negotiations/proffer constituted assent to delay and may justify extending deadlines	Negotiations occurred after the deadline and State offered no evidence negotiations began earlier or that waiver was a term of the deal	No — late negotiations do not retroactively excuse the missed deadline absent evidence of prior reliance or an informed waiver
Whether timeliness of asserting speedy-trial rights (motion filed Dec 8) barred relief	State suggested motion two days before trial was untimely	Defendant argued timely challenge to statutory 90-day rule; earlier assertion not required pretrial	Court treated the timeliness argument as insufficient to negate State’s burden; relief granted because State failed to prove exceptions

Key Cases Cited

Winters v. State, 690 N.W.2d 903 (Iowa 2005) (standard of review and narrowed discretion on speedy-trial rulings)
Ennenga v. State, 812 N.W.2d 696 (Iowa 2012) (no prejudice requirement; failure to assert is not waiver)
Miller v. State, 637 N.W.2d 201 (Iowa 2001) (State bears burden to show waiver, delay attributable to defendant, or good cause)
Nelson v. State, 600 N.W.2d 598 (Iowa 1999) (enumeration of exceptions to mandatory dismissal)
Johnson v. Zerbst, 304 U.S. 458 (1938) (waiver requires intentional relinquishment of a known right)
Zaehringer v. State, 306 N.W.2d 792 (Iowa 1981) (mere acquiescence insufficient; active participation can indicate waiver)
Utter v. State, 803 N.W.2d 647 (Iowa 2011) (discusses plea negotiations, waiver, and ineffective assistance distinctions)
LaMar v. State, 224 N.W.2d 252 (Iowa 1974) (plea negotiations before deadline may justify delay if relied upon)
State v. Sassman, 226 N.W.2d 808 (Iowa 1975) (generalized administrative problems not good cause)
State v. Bond, 340 N.W.2d 276 (Iowa 1983) (general court congestion insufficient; require specific nonrecurring events)