State v. Franklin, S-1-SC-35577

Background

Defendant Bryce L. Franklin was indicted Dec. 17, 2012 for the murder of Fernando Enriquez; he was already incarcerated on unrelated convictions throughout the pretrial period.
Trial began Aug. 10, 2015 — ~32 months after indictment. Franklin moved twice to dismiss for violation of his speedy-trial right (May 1, 2014 and Nov. 17, 2014), and had made an early pro forma demand (Dec. 26, 2012).
District court found the case complex, attributed much delay to administrative/negligent reasons, found Franklin had asserted his speedy-trial right, and found no particularized prejudice because Franklin remained incarcerated on other matters.
The court denied the speedy-trial dismissal; Franklin appealed directly to the New Mexico Supreme Court seeking reversal and dismissal of charges.
The Supreme Court applied the four-factor Barker test, divided the 32-month delay into four periods, weighed each period according to cause, and affirmed the convictions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 32-month delay violated Franklin's Sixth Amendment right to a speedy trial	State: Delay partly administrative; no particularized prejudice; factors do not weigh heavily for dismissal	Franklin: Delay (32 months, ~14 months past complex-case benchmark) violated his speedy-trial rights and warrants dismissal	Denied — delay was presumptively prejudicial but weighed only slightly against the State overall; no particularized prejudice shown, so no violation
Proper start date to measure delay	State: Measure from indictment date, Dec. 17, 2012	Franklin: agreed measurement from indictment	Court: Measure from indictment; indictment triggered speedy-trial right
How to weight reasons for delay (administrative, negligent, defense, valid)	State: Many delays were administrative or justified; some defense-caused continuances	Franklin: State responsible for delay; bad faith or heavier weight warranted	Court: Most delay was administrative/negligent (weighs slightly against State); some periods neutral; defense-caused short delay weighed neutrally because it flowed from State delay
Whether defendant suffered particularized prejudice from delay	State: Franklin remained incarcerated on unrelated matter and did not show lost evidence/witness impairment or undue anxiety	Franklin: Claimed oppressive lockdown conditions and communication difficulties with counsel	Court: Rejected generalized assertions; no specific evidence of oppressive conditions, undue anxiety, or impairment of defense — prejudice not established

Key Cases Cited

Barker v. Wingo, 407 U.S. 514 (sets four-factor speedy-trial balancing test)
State v. Samora, 387 P.3d 230 (N.M. 2016) (applies Barker and explains deference to trial court findings and de novo balancing)
State v. Serros, 366 P.3d 1121 (N.M. 2016) (benchmarks for presumptively prejudicial delay by case complexity)
Salandre v. State, 806 P.2d 562 (N.M. 1991) (speedy-trial right attaches on indictment or arrest and holding to answer)
State v. Garza, 212 P.3d 387 (N.M. 2009) (discusses prejudice types and burden to show particularized prejudice)