214 So. 3d 392
Ala. Crim. App.2016Background
- Pylant was arrested March 29, 2014 for DUI (and criminally negligent homicide); the DUI was nolle prossed April 7, 2014 and later re-indicted August 27, 2014.
- A warrant issued September 12, 2014; Pylant was arrested under that warrant July 2, 2015.
- On July 22, 2015 Pylant pleaded not guilty, waived arraignment, demanded a jury trial, and filed a speedy-trial motion; the State opposed.
- The circuit court granted Pylant’s motion and dismissed the indictment on August 30, 2015; the State appealed.
- The appellate court reviewed de novo under Barker v. Wingo’s four-factor speedy-trial test (length, reasons, assertion, prejudice) and found a 17-month delay presumptively prejudicial but attributable largely to negligent—not deliberate—delay by the State.
- The court concluded Pylant failed to prove actual prejudice (his claim that two eyewitnesses were unavailable was unsubstantiated) and reversed the dismissal, remanding to reinstate the indictment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pylant was denied his Sixth Amendment right to a speedy trial | Pylant argued the 17-month post-accusation delay denied his right to a speedy trial and prejudiced his defense (two eyewitnesses unavailable) | The State argued the delay did not cause sufficient prejudice; most delay was ordinary or negligent and not deliberate | Reversed: delay was presumptively prejudicial but weighed the Barker factors; negligent delay only lightly against State and Pylant failed to prove actual prejudice, so dismissal was unwarranted |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (establishes four-factor speedy-trial balancing test)
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (discusses presumptive prejudice and when delay triggers Barker inquiry)
- Ex parte Walker, 928 So.2d 259 (Ala. 2005) (Alabama application of Barker, guidance on weighing delay and prejudice)
- Ex parte Heard, 999 So.2d 978 (Ala. 2003) (standard for de novo review when facts undisputed)
- United States v. Serna-Villarreal, 352 F.3d 225 (5th Cir. 2003) (treats negligent delay and when prejudice may be presumed)