State Of Washington, V. Skyler G. Yzaguirre, 80660-2

On Oct. 19, 2018, Yzaguirre was arrested after a DUI collision and charged with felony DUI and related offenses; a blood sample was sent for toxicology.
He was arraigned Nov. 1, 2018, held in custody, and the CrR 3.3 speedy trial date was calculated to expire Dec. 31, 2018.
On Dec. 13, 2018, the court granted the State’s continuance request (lab delay) and set trial for Jan. 7, 2019; Yzaguirre objected and did not sign a waiver of speedy trial.
The State requested further continuances for unavailable toxicology results and an unavailable officer; the court conditionally released Yzaguirre on Jan. 10, 2019.
Yzaguirre failed to appear and was rearrested Feb. 8, 2019; he remained in custody until trial in Aug. 2019 and was convicted.
At sentencing the court found Yzaguirre indigent but left form language imposing community custody supervision fees; the Court of Appeals affirmed the convictions but remanded to strike the supervision fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy trial (CrR 3.3 / constitutional right)	Yzaguirre: continuance pushed trial past speedy date without waiver and violated his speedy trial rights.	State: continuances were required for toxicology results and officer availability; delay (10 days past Dec. 31) was not presumptively prejudicial and did not prejudice defendant.	No violation. 10-day extension was for administration of justice, not presumptively prejudicial; CrR 3.3 and Barker balancing not triggered.
Community custody supervision fees (LFOs)	Yzaguirre: court found him indigent and intended to waive discretionary LFOs, so supervision-fee language is erroneous.	State: supervision fees are discretionary LFOs (but the record shows court intended to waive).	Remand to strike community custody supervision fees from the judgment and sentence.

State v. Hatt, 11 Wn. App. 2d 113 (2019) (discussing CrR 3.3 speedy-trial timing and excluded continuances)
State v. Ollivier, 178 Wn.2d 813 (2013) (Washington speedy-trial analysis parallels Sixth Amendment)
Barker v. Wingo, 407 U.S. 514 (1972) (four-factor balancing test for constitutional speedy-trial claims)
State v. Iniguez, 167 Wn.2d 273 (2009) (delay must be presumptively prejudicial to trigger Barker analysis)
State v. Salgado-Mendoza, 189 Wn.2d 420 (2017) (concerns about lab delays and potential prejudice to defendants)
State v. Peña Salvador, 487 P.3d 923 (Wash. Ct. App. 2021) (community custody supervision fees are discretionary LFOs and remand may be required if court intended to waive them)
State v. Dillon, 12 Wn. App. 2d 133 (2020) (remand to strike supervision fees where record shows intent to impose only mandatory LFOs)