State v. Medina, A-1-CA-35919

Defendant Vicente Charles Medina was indicted for possession of cocaine on October 2, 2014; he pleaded guilty conditionally, reserving a speedy-trial challenge.
Nearly 22 months elapsed between indictment and trial, exceeding the 12-month guideline for a "simple" case.
Defendant waived three months of delay; the court treated the remaining seven-month delay as weighing slightly in his favor.
The district court found the reasons for delay were attributable to both parties; defendant made pro forma speedy-trial demands and an eve-of-trial motion to dismiss.
Defendant alleged generalized prejudice (faded witness memories; stress from release conditions like firearm and alcohol restrictions) but did not identify particularized impairment to his defense.
The Court of Appeals reviewed the district court’s factual findings for deference but addressed the constitutional question de novo and affirmed the denial of dismissal.

Issue	State's Argument	Medina's Argument	Held
Whether Medina’s Sixth Amendment right to a speedy trial was violated by ~22 months pretrial delay	Delay did not amount to a constitutional violation because reasons for delay were partly defendant-caused, prejudice was not particularized, and defendant acquiesced in part	Delay was presumptively prejudicial (exceeded 12-month guideline); need relief without particularized prejudice given length and reasons for delay	Affirmed. Although delay was presumptively prejudicial and seven months favored Medina, reasons were shared, defendant asserted only pro forma demands, and he failed to show particularized prejudice, so no speedy-trial violation was found.

State v. Montoya, 150 N.M. 415, 259 P.3d 820 (N.M. Ct. App. 2011) (initial inquiry: whether pretrial delay is presumptively prejudicial)
State v. Fierro, 315 P.3d 319 (N.M. Ct. App. 2014) (articulates four-factor speedy-trial balancing test)
State v. Garza, 146 N.M. 499, 212 P.3d 387 (N.M. 2009) (guidelines for presumptive prejudice by case complexity)
State v. Lujan, 345 P.3d 1103 (N.M. Ct. App. 2015) (treats seven-month excess delay as weighing in defendant’s favor)
State v. Brown, 134 N.M. 356, 76 P.3d 1113 (N.M. Ct. App. 2003) (defer to district court findings; review right de novo)
State v. Spearman, 283 P.3d 272 (N.M. 2012) (discusses requirement of particularized prejudice)
State v. Stock, 140 N.M. 676, 147 P.3d 885 (N.M. Ct. App. 2006) (general allegations of faded memory insufficient to show actual prejudice)