State v. Reynolds, 196 Vt. 113

Defendant Stanley Reynolds was charged with sexual assault without consent on March 3, 2010 and released on bail.
ASL interpreters were required for two key witnesses, creating extensive trial scheduling challenges.
The first jury trial, begun March 2011, ended in a mistrial due to significant interpretive problems.
A new defense counsel was appointed at state expense after Goldsborough withdrew; the court postponed trial and issued continuances.
Multiple status conferences and orders addressed interpreter needs, scheduling, and continuances, culminating in a second trial date of February 13–16, 2012.
Trial proceeded in February 2012 resulting in a guilty verdict and a sentence of five years to life; Reynolds appeals on speedy-trial grounds and prosecutorial closing arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the delay between arraignment and the second trial violated speedy-trial rights	Reynolds argues the nearly two-year delay was presumptively prejudicial and unconstitutional.	State contends delays were neutral or attributable to defense needs and interpreter logistics; not a constitutional violation.	No speedy-trial violation; delay was not prejudicial under Barker factors.
Whether prosecutorial closing arguments were improper and prejudicial	Prosecutor appealed to jury sympathy for the victim, urging them to deliver justice.	Prosecutor’s remarks improperly sought jury sympathy and justice for the victim.	Any prosecutorial misconduct was harmless error; did not prejudice the verdict.

Barker v. Wingo, 407 U.S. 514 (1972) (four-factor speedy-trial balancing framework)
Brillon v. State, 183 Vt. 475, 955 A.2d 1108 (2008) (recognizes mixed standard; delays due to court/prosecution weighed)
Vermont v. Brillon, 556 U.S. 81 (2009) (recognizes defense-counsel-delays attributed to defendant)
State v. Savva, 159 Vt. 75, 616 A.2d 774 (1991) (Vermont constitution comparison; Barker framework applicable)
State v. Venman, 151 Vt. 561, 564 A.2d 574 (1989) (Vermont speedy-trial analysis; Barker standard applied)
State v. Hall, 145 Vt. 299, 487 A.2d 166 (1984) (Vermont constitutional speedy-trial implications)
State v. Mahoney, 124 Vt. 488, 207 A.2d 143 (1965) (speedy-trial considerations under Vermont constitution)
State v. Snide, 144 Vt. 436, 479 A.2d 139 (1984) (procedural framework for reviewing speedy-trial claims)
State v. Mumley, 2009 VT 48, 186 Vt. 52, 978 A.2d 6 (2009) (plain-error standard in prosecutorial-misconduct review)
State v. Ayers, 148 Vt. 421, 535 A.2d 330 (1987) (plain-error review framework for prosecutorial conduct)
State v. Blakeney, 137 Vt. 495, 408 A.2d 636 (1979) (prosecutorial misconduct considerations in closing argument)