State v. Mayes
2016 Mont. LEXIS 1005
Mont.2016Background
- Mayes was arrested Aug 7, 2014 for felony possession of a syringe testing positive for methamphetamine; bond set and information filed mid-August.
- The State Crime Lab reported a backlog (7–9 months); the sheriff’s office was told the syringe contents needed vials, but the State waited 102 days to submit the sample for testing.
- Trial initially set for Feb 9, 2015 (186 days after arrest); State moved for continuance due to expected delayed lab results and the court reset trial to May 19, 2015 (285 days after arrest).
- Mayes remained in county jail from arrest until guilty plea on May 13, 2015 (279 days); he objected to continuance and moved to dismiss for speedy-trial violation.
- District Court denied dismissal after applying the Ariegwe balancing test; Montana Supreme Court reversed, finding the 102-day unexplained submission delay and lost rehabilitative opportunity compelled dismissal.
Issues
| Issue | Mayes’ Argument | State’s Argument | Held |
|---|---|---|---|
| Whether delay exceeded speedy-trial trigger | Total delay 279 days > 200-day Ariegwe trigger; presumption of prejudice | Delay attributable largely to lab backlog and parole status; not prejudicial | Court: Delay exceeded trigger (79 days over) and favors Mayes |
| Whether reasons for delay weigh against State | 102-day failure to submit sample shows lack of diligence (or worse) and is attributable to State | Delay was institutional (lab backlog) and not deliberate; State not solely culpable | Court: Reasons weigh heavily against State (not bad faith but more than mere negligence) |
| Whether Mayes asserted and wanted a speedy trial | Timely objected to continuance and filed motion to dismiss; plea does not negate prior speedy-trial claim | Plea indicates he ultimately waived interest in trial speed | Court: Mayes timely asserted the right and plea does not erase speedy-trial violation claim |
| Whether Mayes was prejudiced by the delay | Prejudice includes oppressive pretrial incarceration and lost rehab placement (pre-screened and accepted) | No specific proof of impaired defense, anxiety not substantiated; parole status caused continued custody | Court: Prejudice found—lost access to DOC treatment/community placement and nature of charge (simple drug possession) support relief |
Key Cases Cited
- State v. Ariegwe, 338 Mont. 442, 167 P.3d 815 (2007) (Montana’s four-factor speedy trial balancing framework)
- State v. Velasquez, 384 Mont. 447, 377 P.3d 1235 (2016) (prosecution’s failure to pursue alternatives to a backlogged lab can show lack of diligence)
- State v. Billman, 346 Mont. 118, 194 P.3d 58 (2008) (lengthy pretrial incarceration on simple charges can establish prejudice)
- Barker v. Wingo, 407 U.S. 514 (1972) (Supreme Court balancing test and caution that factors have no talismanic weight)
- Doggett v. United States, 505 U.S. 647 (1992) (presumption of prejudice increases with delay; three interests protected by speedy-trial right)
- State v. Betterman, 378 Mont. 182, 342 P.3d 971 (2015) (discussion of remedies and relation of plea to speedy-trial timing)