State v. Steigelman
2013 MT 153
| Mont. | 2013Background
- Steigelman was charged with felony DUI and two misdemeanors in Yellowstone County in 2009.
- He moved to dismiss the charges on speedy-trial grounds in June 2010; the district court denied.
- The court later held a hearing and credited most delay to the State as institutional delay.
- Steigelman eventually pled guilty to DUI; the State dropped the two misdemeanors.
- The issue on appeal is whether the State violated Steigelman’s right to a speedy trial; the Montana Supreme Court affirms the district court’s denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a speedy-trial violation? | Steigelman argues the delay violated his right to a speedy trial. | State contends delays were mostly institutional and justified. | No speedy-trial violation; delay justified by institutional delay and lack of prejudice. |
Key Cases Cited
- Ariegwe, 338 Mont. 442, 167 P.3d 815 (MT 2007) (framework for balancing factors of Barker v. Wingo; de novo legal questions, factual findings reviewed for clear error)
- Billman, 346 Mont. 118, 194 P.3d 58 (MT 2008) (200-day trigger; prejudice and scheduling impact analyzed)
- Couture, 357 Mont. 398, 240 P.3d 987 (MT 2010) ( State bears heavy burden to show absence of prejudice after long delays)
- Lacey, 355 Mont. 31, 224 P.3d 1247 (MT 2010) (delays and defendant’s actions; prejudice considerations under extended delays)
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (presumptive prejudice from excessive delay; not required to prove concrete prejudice in every case)
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (balancing test for speedy-trial claims (length, reasons, defendant’s actions, prejudice))