State v. Nickerson, 2014 MT 83

In August 2007 Flathead County charged Damien Nickerson with felony burglary and issued an arrest warrant the same day.
Shortly after, Nickerson was arrested on unrelated federal charges, convicted, and has been incarcerated in federal prison (Oregon) since 2007.
In August 2013 Nickerson (pro se) moved to dismiss the Flathead County arrest warrant, alleging the State violated his Sixth Amendment right to a speedy trial by delaying prosecution for over six years.
He attached a 2011 Bureau of Prisons “Detainer Action Letter” addressed to the Kalispell County Sheriff asking whether a detainer should be lodged, but the record does not show a detainer was ever filed.
The Flathead County Attorney responded treating the motion as an Interstate Agreement on Detainers (IAD) claim and argued the IAD does not apply because no detainer was filed. The district court denied the motion without explanation.
The Montana Supreme Court reversed, holding the district court failed to address Nickerson’s constitutional speedy-trial claim and remanded for analysis under the Ariegwe speedy-trial factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by denying Nickerson’s motion to dismiss without addressing his Sixth Amendment speedy-trial claim	Nickerson argued the State’s six-year delay violated his Sixth Amendment right to a speedy trial and sought dismissal of the warrant/charge	State characterized the motion as an IAD claim and argued IAD does not apply because no detainer was filed	Court held the district court erred: it must consider Nickerson’s constitutional speedy-trial claim (not just IAD issues) and remanded for application of the Ariegwe factors

Carchman v. Nash, 473 U.S. 716 (1985) (IAD is an interstate compact subject to federal construction)
Cuyler v. Adams, 449 U.S. 433 (1981) (compact/consent-clause principles informing interstate agreements)
United States v. Mauro, 436 U.S. 340 (1978) (IAD provisions are triggered only after a detainer is filed)
Smith v. Hooey, 393 U.S. 374 (1969) (custody in federal prison does not excuse a State’s speedy-trial obligations)
Tinghitella v. California, 718 F.2d 308 (9th Cir. 1983) (constitutional speedy-trial inquiry distinct from IAD; IAD absence does not end speedy-trial inquiry)
Moore v. Arizona, 414 U.S. 25 (1973) (pending charges can affect parole and rehabilitation—speedy-trial considerations remain important)
Strunk v. United States, 412 U.S. 434 (1973) (speedy-trial protections and remedy of dismissal)
State v. Seadin, 593 P.2d 451 (Mont. 1979) (IAD provisions bind a receiving state only after a detainer is filed)