State v. Cahill
213 N.J. 253
| N.J. | 2013Background
- Cahill caused a car crash after drinking; Alcotest indicated BAC > .08.
- He was charged with DWI, reckless driving, consumption of alcohol in a vehicle, open container, and aggravated assault; indicted for assault by auto.
- A 2008 indictment for assault by auto was resolved with Cahill pleading guilty to fourth-degree assault by auto and receiving probation.
- The DWI charges were remanded to municipal court and remained pending for 16 months before trial notice.
- Sixteen-month delay between remand and trial notice occurred with no explanation; Cahill alleged speedy-trial violation and prejudice from anxiety and employment impact.
- The Court reaffirmed Barker four-factor test for speedy-trial claims in quasi-criminal municipal matters and discussed Directive #1-84 and later Directive #04-11 guiding disposition timelines and procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Barker four-factor test governs speedy-trial claims for quasi-criminal charges. | Cahill argues Barker applies to quasi-criminal driving charges. | State argues Barker applies but seeks no bright-line rule. | Barker test governs all criminal/quasi-criminal matters. |
| Is a sixteen-month unexplained delay in remanded DWI charges unconstitutional? | Delay is inordinate and prejudicial to Cahill. | Delay was due to State handling; not inherently prejudicial. | Yes; sixteen-month delay is inordinate and violates speedy-trial rights. |
| Did Cahill's failure to assert the right before trial notice defeat his claim? | Delay should be weighed against State neglect; assertion timing not dispositive. | Non-assertion weighs against defendant. | Failure to assert is not dispositive; State negligence drives result. |
| What is the appropriate remedy for a speedy-trial violation here? | Dismissal of the DWI charge is appropriate. | Dismissing only the municipal charge is excessive given context. | Dismissal of the municipal DWI charge is the proper remedy. |
| Should a bright-line time limit govern speedy-trial disposition for DWI in municipal courts? | A clear standard would aid fairness and public safety. | Case-by-case Barker approach better accommodates varied facts. | No bright-line rule; continue case-by-case Barker analysis with directives. |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (establishes four-factor speedy-trial test)
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (relevance of customary time to disposition; presumptive prejudice threshold)
- State v. Perkins, 219 N.J. Super. 121 (Law Div. 1987) (illustrates case-by-case Barker analysis in DWI context)
- State v. Berezansky, 386 N.J. Super. 84 (App. Div. 2006) (discusses delays and Barker factors in DWI cases)
- State v. Prickett, 240 N.J. Super. 139 (App. Div. 1990) (case-specific Barker analysis for delays in DWI)