State v. Steigelman, 302 P.3d 396

Steigelman was charged with felony DUI and two misdemeanors after a July 29, 2009 arrest for allegedly driving intoxicated and striking a road sign.
He appeared for arraignment August 3, 2009; bail was set on August 6, 2009 after eight days in jail.
The omnibus hearing was initially set for November 9, 2009 and trial for January 19, 2010, but Steigelman failed to appear at the omnibus hearing and counsel sought a continuance.
A scheduling conflict with a triple homicide case caused his trial date to be moved multiple times, resulting in a long pretrial delay attributed largely to institutional State delay.
Key delays included 174 days from arrest to first trial date, 140 days between first and second trial dates, and 112 days between second and third trial settings, with the latter attributed to defense requests.
Steigelman moved to dismiss on June 1, 2010 claiming a violation of the speedy-trial right; after hearings the district court found substantial delay largely due to the State but denied dismissal, and he ultimately pled guilty to DUI with misdemeanors dropped.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State violated Steigelman's speedy-trial right.	Steigelman	State	No speedy-trial violation; factors balance in State's favor.
Whether the delay was attributed to institutional State delay.	Steigelman	State	Majority attributed 314 days to institutional delay; total exceeds 200-day trigger.
Whether the delay caused prejudice to Steigelman’s defense.	Steigelman	State	Prejudice not shown; delay did not impair ability to defend.

Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (speedy-trial balancing framework adopting four-factor test)
State v. Ariegwe, 338 Mont. 442, 167 P.3d 815 (Mont. 2007) (multi-factor speedy-trial analysis; factor weight varies with case)
State v. Billman, 346 Mont. 118, 194 P.3d 58 (Mont. 2008) (lengthier delays require stronger justification; prejudice considerations evolve)
State v. Stops, 370 Mont. 226, 301 P.3d 811 (Mont. 2013) (institutional delay vs. intentional delay; prejudice considerations on review)
Doggett v. United States, 505 U.S. 647 (U.S. 1992) (presumptive prejudice for excessive delay; not always required to prove actual prejudice)
State v. Couture, 357 Mont. 398, 240 P.3d 987 (Mont. 2010) (heavy State burden to show lack of prejudice for long delays)
State v. Lacey, 355 Mont. 31, 224 P.3d 1247 (Mont. 2010) (lengthy delays with proving prejudice may be mitigated by other factors)
State v. Hardaway, 351 Mont. 488, 213 P.3d 776 (Mont. 2009) (precedent on prejudice and delay considerations in speedy-trial claims)