State v. Ollivier, 312 P.3d 1

Ollivier, a registered sex offender, was jailed for 23 months awaiting trial following 22 continuances largely requested by defense counsel.
The court allowed these continuances under CrR 3.3(f)(2); Ollivier did not object to the initial continuances but objected to most later ones.
A search warrant for Ollivier’s apartment was based on an affidavit containing a misstatement about a red box of pornography; the warrant was executed, and property was seized after detectives posted a copy of the warrant.
Forensic analysis found extensive child pornography on Ollivier’s computers; he was convicted of possession of depictions of minors engaged in sexually explicit conduct.
The Court of Appeals affirmed the conviction; the Supreme Court held there was no constitutional speedy-trial violation and that the warrant affidavit, once misrepresentations are redacted, still supported probable cause; CrR 2.3(d) did not require pre-search delivery of the warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 23-month delay violated CrR 3.3 speedy-trial rules	Ollivier argues delay exceeding statutory limits violated CrR 3.3	State contends defense counsel’s continuances were proper and did not prejudice	No CrR 3.3 violation; delay attributable to Ollivier’s defense preparations.
Whether the delay violated constitutional speedy-trial rights	Ollivier asserts presumption of prejudice and rights were violated	State argues delays were defense-driven and no prejudice shown	No constitutional violation; Barker factors weigh against Ollivier, with prejudice not shown.
Sufficiency of probable cause after redaction of misrepresentations	Redacted affidavit lacked probable cause	Redacted facts still establish probable cause	Probable cause remains after redactions; warrant valid.
CrR 2.3(d) requirement to provide copy of warrant before search	Ollivier claims no copy was provided pre-search	Rule allows posting copy if no one present	No violation; a copy was posted during the seizure.

Doggett v. United States, 505 U.S. 647 (U.S. 1992) (presumed prejudice for lengthy delays; Barker framework guiding analysis)
Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (balance factors for speedy-trial claims; threshold presumptive prejudice)
Iniguez, 67 Wn.2d 273? hmm (2009) (Washington parallel to Sixth Amendment analysis; Barker factors)
State v. Campbell, 103 Wn.2d 1 (Wash. 1984) (counsel may waive trial date to ensure effective representation)
Britton (Britton v. United States?), 556 U.S. 81 (U.S. 2009) (delay caused by defense counsel weighs against defendant; Brillon discussion)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality of suppressed evidence; Brady-related discussion)
Chamberlin, 161 Wn.2d 30 (Wash. 2007) (confidential/informant reliability standard Aguilar/Spinelli applied)
Lyons, 174 Wn.2d 354 (Wash. 2012) (adopts Aguilar/Spinelli for informants; reliability assessment)
Aguilar v. Texas, 378 U.S. 108 (U.S. 1964) (Abandoned in Gates; still cited for informant credibility framework)