State v. Helt, 35,238

Helt was convicted in Lea County of aggravated battery with a deadly weapon and appeals the verdict on a speedy-trial claim.
The memorandum indicates an unpublished disposition and discusses preservation of the appeal a conditional plea claimed by Helt.
The court assumed, for purposes of argument, that Helt preserved the right to appeal the speedy-trial issue.
The record suggested an approximately fifteen-month delay from offense to trial, which the court characterized as potentially intermediate in complexity.
The panel concluded that even if the case were simple, the delay would exceed the threshold by at most three months, and the delay weighed only slightly against the state.
The court rejected claims of substantial prejudice or particularized harm due to the delay and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Helt's speedy-trial right violated by the delay?	Helt argued the delay surpassed the speedy-trial threshold.	The delay should be treated as longer than allowed for a simple case, constituting a violation.	No violation; delay only slightly favored the defendant and showed no particularized prejudice.

State v. Rojo, 126 N.M. 438 (1999-NMSC-001) (complexity and record sufficiency govern review when record is doubtful)
State v. Manzanares, 121 N.M. 798 (1996-NMSC-028) (case complexity determined by district court familiar with facts and issues)
State v. Jim, 107 N.M. 779 (1988-NMCA-092) (burden on defendant to provide a record sufficient for review)
State v. Suskiewich, 363 P.3d 1247 (2016-NMCA-004) (fourth factor weighs slightly in defendant’s favor when no explicit trial demand)
State v. Garza, 146 N.M. 499 (2009-NMSC-038) (particularized prejudice required; without it speedy-trial rights not violated)
State v. Wilson, 147 N.M. 706 (2010-NMCA-018) (delay beyond guideline for simple case weighs only slightly against state)
State v. Samora, 387 P.3d 230 (2016-NMSC-031) (negligent or administrative delay must be considered; ultimate responsibility with state)