State v. J. Saunders, 2021 MT 183N

Saunders was arrested July 9, 2017, and charged by information on August 2, 2017 with burglary and four counts of felony theft.
He was held on $200,000 bail, did not post bond, and remained incarcerated from arrest until trial — 423 days total.
The case saw multiple appointed OPD counsel substitutions and several continuances; the district court’s own calendar changes also led to rescheduling of trial dates.
Trial ultimately set for September 5–6, 2018; Saunders moved to dismiss for a speedy-trial violation on August 2, 2018; the district court denied the motion on August 30, 2018.
Jury convicted Saunders of burglary and three theft counts; he was sentenced to concurrent terms (20 years, 15 suspended), restitution, and credited with 494 days served.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Saunders was denied his constitutional right to a speedy trial	No — although delay exceeded 200 days, the State lacked bad faith and showed reasons for delay; no prejudice proven	Yes — 423-day delay presumptively prejudicial and violated his speedy-trial right	Court affirmed denial of dismissal after balancing the four Barker/Ariegwe factors; no violation found
Attribution of delay (who is responsible)	Much delay was institutional or due to court scheduling; some attributable to Saunders but not bad faith by State	Continuances caused by OPD substitutions/availability should be charged to the State (systemic OPD problems)	Court attributed segments to State (institutional) and to Saunders (counsel continuances); found no systemic public‑defender breakdown per Brillon
Saunders’ response to delay (did he assert the right timely)	Saunders rarely and late asserted speedy-trial concerns; motion filed only in Aug 2018	Saunders points to earlier complaints about counsel and bail hearings as showing concern	Court found objections untimely/insincere; this factor weighed for the State
Prejudice from delay	No specific prejudice shown: incarceration was not oppressive given charges/history; no impairment of defense shown	Pretrial incarceration, life disruption, and potential witness memory loss impaired defense	Court found insufficient evidence of prejudice (esp. impairment of defense, the most important subfactor)

State v. Steigelman, 370 Mont. 352, 302 P.3d 396 (2013) (review standards for speedy-trial constitutional claims; factual findings for clear error)
State v. Ariegwe, 338 Mont. 442, 167 P.3d 815 (2007) (articulates four-factor speedy-trial balancing test and 200-day trigger for analysis)
Vermont v. Brillon, 556 U.S. 81 (2009) (delay caused by assigned counsel is generally attributable to the defendant absent a systemic public‑defender breakdown)