State v. Charles, 263 P.3d 469

Defendant Billy Charles was convicted in 2009 of first-degree murder for his girlfriend's death in August 1996 following a homicide determination by the medical examiner.
The State charged Charles eleven years after the death; he contends preaccusation delay violated due process and that the delay allowed evidence loss, a witness death, and hindered defense development.
During trial, the State presented a jailhouse informant whose credibility was attacked by Charles on grounds including the informant's criminal history and exchange incentives, and the timing of sentencing for the informant after trial raised concerns.
Charles asserted trial counsel was ineffective for not subpoenaing a cousin who could implicate a third party and for failing to present other corroborating witnesses (grandmother, neighbor, and a mechanic) to support his alibi about the truck and girlfriend's involvement.
The trial court gave a general cautionary jury instruction regarding jailhouse informant testimony; Charles urged a more specific instruction tailored to jailhouse informants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preaccusation delay due process	Charles must show bad faith and prejudice via delay.	Eleven-year delay violated due process and prejudiced defense.	Delay did not violate due process; no showing of bad faith.
Independent due process claim from investigation	Investigation failures violated due process by neglecting other leads.	State recklessly or intentionally ignored exculpatory leads.	No due process violation from investigative conduct; no showing of reckless/intentional misconduct.
Ineffective assistance of counsel	Defense failures to call witnesses and corroborating testimony undermined defense.	Counsel's omissions could have produced a reasonable doubt.	Counsel's failures to secure certain witnesses were deficient and, when combined with the totality of evidence, created a reasonable probability of a different outcome; conviction reversed and remanded for new trial.
Jailhouse informant jury instruction	The court's instruction adequately cautioned jurors on informant credibility.	A more specific jailhouse informant instruction was warranted.	Better, more specific jailhouse informant instruction would have been helpful; not dispositive due to reversal on other grounds.

State v. Hales, 2007 UT 14 (Utah Supreme Court, 2007) (preaccusation delay requires showing actual prejudice and bad faith)
Chen v. Stewart, 2004 UT 82 (Utah Supreme Court, 2004) (constitutional due process and delay principles)
State v. Messer, 2007 UT App 166 (Utah Appellate Court, 2007) (weighing jailhouse informant testimony and jury instructions)
State v. Van Matre, 777 P.2d 459 (Utah Supreme Court, 1989) (due process and investigation standards context)