State v. J. Chambers, 474 P.3d 1268

June 13, 2012: Fergus County filed an information charging John W. Chambers with burglary and theft; he was served with an arrest warrant on June 15, 2012.
Chambers had been arrested May 11, 2012 for unrelated Stillwater County burglaries and was sentenced in Feb. 2013 to concurrent 20-year terms; he was serving that sentence at Montana State Prison.
Fergus County lodged a detainer; the detainer was confirmed by MSP on June 6, 2013, but Chambers remained incarcerated on the Stillwater sentence.
No trial on the Fergus County charges occurred for nearly five years (total delay = 2,066 days); Chambers filed a pro se motion to dismiss for speedy trial violation on June 30, 2017 and later renewed it through counsel.
The Tenth Judicial District denied the motions; Chambers pleaded guilty reserving the right to appeal the denial. The Montana Supreme Court reviewed the speedy-trial claim de novo and dismissed the charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Chambers was denied his constitutional right to a speedy trial by a ~5-year pretrial delay	State: Delay was not unduly oppressive because Chambers was already incarcerated on unrelated charges and institutional/prison constraints justified the delay	Chambers: State knew his location, took no steps to bring him to trial despite using a detainer, filed motion before trial, and suffered prejudice (parole impact, lost chance for concurrent sentencing)	Court: Speedy-trial right violated; all four Barker/Ariegwe factors weigh against the State; charges dismissed

State v. Ariegwe, 338 Mont. 442, 167 P.3d 815 (2007) (Montana four-factor speedy-trial balancing framework).
Barker v. Wingo, 407 U.S. 514 (1972) (U.S. Supreme Court establishing speedy-trial balancing test).
State v. Betterman, 378 Mont. 182, 342 P.3d 971 (2015) (remedy for a speedy-trial violation is dismissal).
State v. Highpine, 303 Mont. 422, 15 P.3d 938 (2000) (prior incarceration on unrelated charges does not automatically preclude showing prejudice).
State v. Hodge, 377 Mont. 123, 339 P.3d 8 (2014) (government negligence in prosecution weighs heavily against the State).
State v. Stewart, 386 Mont. 315, 389 P.3d 1009 (2017) (speedy-trial constitutional questions reviewed de novo).
State v. Butterfly, 384 Mont. 287, 377 P.3d 1191 (2016) (same standard of review for constitutional speedy-trial claims).
State v. Morsette, 372 Mont. 38, 309 P.3d 978 (2013) (factual findings in speedy-trial analysis reviewed for clear error).
State v. Blair, 324 Mont. 444, 103 P.3d 538 (2004) (defendant has no obligation to ensure diligent prosecution).