State of Iowa v. Shawn Michael Elder Jr., 2015 Iowa App. LEXIS 338

Shawn Michael Elder Jr. was charged with manufacture of >5 grams of methamphetamine after arraignment on November 5, 2012; trial was originally set for January 8, 2013.
Multiple continuances followed: Elder waived speedy trial once, then requested five continuances for reasons including depositions, counsel scheduling conflicts, and pending motions; the State also sought consolidation with a co-defendant’s case.
The district court consolidated Elder’s case with a co-defendant, later expressed conflict concerns, and eventually granted Elder’s motion to sever on October 21, 2013.
On October 9, 2013 the State moved to continue trial beyond the one‑year limit; the district court granted the extension, citing “good cause” based on case history, docket pressures, and counsel scheduling.
Elder moved to dismiss on speedy‑trial grounds (one‑year rule); the court denied dismissal and Elder was tried and convicted on November 13, 2013—eight days after the one‑year deadline.
The Court of Appeals reversed, holding the State failed to meet its burden to prove delay beyond one year was attributable to Elder or otherwise justified by good cause, and remanded for dismissal.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Elder)	Held
Whether the court properly granted continuance beyond the one‑year speedy‑trial deadline and denied dismissal	The State argued good cause existed because of multiple prior scheduling changes, the county docket pressures, and counsel scheduling conflicts	Elder argued the State failed its heavy burden to show good cause; any defense continuances did not make trial beyond one year a practical necessity	Reversed: Court held the State did not prove good cause or that delay was attributable to Elder; dismissal required

State v. Miller, 637 N.W.2d 201 (Iowa 2001) (State bears burden to show exception to speedy‑trial rule)
State v. Campbell, 714 N.W.2d 622 (Iowa 2006) (focus on reason for delay; defendant‑attributable delay must be practical necessity)
State v. Mary, 401 N.W.2d 239 (Iowa Ct. App. 1986) (one‑year rule is an outer limit; State’s burden to justify extension is heavy)
State v. Nelson, 600 N.W.2d 598 (Iowa 1999) (general court congestion insufficient to excuse speedy‑trial violation)
State v. Bond, 340 N.W.2d 276 (Iowa 1983) (distinguish chronic congestion from unique nonrecurring scheduling problems)
State v. Leonard, 240 N.W.2d 690 (Iowa 1976) (court must explain why other matters took precedence; extraordinary measures may be required to meet speedy‑trial deadlines)