State v. Pickett, 288 Ga. 674

Pickett was arrested on June 23, 2003 for molesting his ten-year-old daughter and released on bond July 2, 2003 with a no-contact-with-children condition.
Indictment on multiple child-sex offenses followed on April 7, 2006.
Bond existing condition prevented contact; request to amend bond for supervised contact denied May 29, 2007.
No trial calendar was set; Pickett could not afford a psychologist; no court-ordered report for bond modification.
On November 19, 2008 Pickett moved to dismiss the indictment for speedy-trial violation; December 15–17, 2008 court granted the motion; Court of Appeals affirmed, and this Court granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the delay was presumptively prejudicial	State: delay was long enough to trigger Barker analysis	Pickett: delay presumptively prejudicial under Barker framework	Delay was presumptively prejudicial and required Barker analysis
Whether Barker factors were correctly applied, including assertion of the right and prejudice	State: trial court properly weighed factors	Pickett: court misapplied Barker, especially assertion-of-right and prejudice	Court rejected improper Barker application; remand required for correct analysis
Whether Court of Appeals erred in affirming rather than remanding for proper Barker analysis	State: appellate court should affirm	Pickett: appellate court erred by substituting its own Barker weighing	Court of Appeals erred; judgment reversed and remanded for proper findings and analysis

Ruffin v. State, 284 Ga. 52 (2008) (presumptive prejudice threshold for speedy trial inquiry; Barker framework applied)
Barker v. Wingo, 407 U.S. 514 (1972) (four-factor balancing test for speedy trial claims)
Doggett v. United States, 505 U.S. 647 (1992) (ad hoc balancing and prejudice assessment in Barker analysis)
Sweatman v. State, 287 Ga. 872 (2010) (delay and prejudice considerations; no automatic dismissal in absence of deliberate delay)
Brown v. State, 287 Ga. 892 (2010) ( weighing of assertion-of-right factor where delay was lengthy; burden on court to assess delay specifics)
Layman v. State, 284 Ga. 83 (2008) (long delays weighed against defendant under Barker)
Porter, 288 Ga. 524 (2011) (guidance on calculating delay to trigger Barker analysis; appellate review of Barker balancing)
Higgenbottom v. State, 288 Ga. 429 (2011) (need for Barker analysis to be consistent with findings of fact and legal conclusions)
Williams v. State, 277 Ga. 598 (2004) (guide on discretionary deference to trial court in Barker context)