State v. Steinmetz
2014 NMCA 070
N.M. Ct. App.2014Background
- Steinmetz was indicted in April 2009 on multiple counts alleging sexual abuse of his daughter (Nov. 2006–Nov. 2008). The case remained pending ~43 months when the district court dismissed for violation of the Sixth Amendment speedy trial right. The State appealed.
- The appellate court applied the four-factor speedy-trial balancing test (length of delay; reasons for delay; assertion of right; prejudice) and reviewed de novo.
- The court characterized the case as of intermediate complexity (triggering a 15-month presumption point); the defense–prosecution timeline was parsed into ten periods to allocate responsibility for delays.
- After examining filings, substitutions of defense counsel, Defendant’s pro se filings, motions that he filed or caused, periods of illness/surgery, and periods of prosecutorial understaffing/administrative delay, the court attributed most delay to Defendant.
- The appellate court concluded: the length of delay weighed moderately against the State, but the reasons-for-delay factor weighed heavily against Defendant (~34 of 43 months caused by Defendant); Defendant’s repeated, often nominal speedy-trial claims and delay-causing conduct undercut his assertions; prejudice to Defendant was shown mostly by testimony but was largely self-inflicted and therefore weighed only slightly in his favor.
- Holding: reversal of the district court’s dismissal; remand for further proceedings.
Issues
| Issue | State's Argument | Steinmetz's Argument | Held |
|---|---|---|---|
| Whether Defendant’s Sixth Amendment speedy trial right was violated by ~43 months of delay | Dismissal was erroneous because most delay was attributable to Defendant (counsel substitutions, pro se filings, motions, failure to prepare); limited periods of administrative delay do not warrant dismissal | Delay length and some prosecutorial/administrative gaps violated the right and caused prejudice (anxiety, onerous conditions of release) | Reversed dismissal — speedy-trial right not violated on balance; most delay attributable to Defendant |
| Proper allocation of periods of delay between State and Defendant | Many intervals were caused by defense actions; State acted to provide discovery and request dates | State failed to timely act in some intervals | Appellate court reallocated many intervals to Defendant; only ~2.5 months weighed against State and ~4 months neutral |
| Weight to give Defendant’s assertions of the right | Defendant’s repeated perfunctory assertions (some filed while causing delay) show gamesmanship; assertion factor should not favor him | Defendant repeatedly filed speedy-trial motions and demands; he contends he asserted right | Assertion factor given no weight for Defendant (not credited) |
| Prejudice from the delay sufficient to require dismissal | Prejudice shown (anxiety, restrictions) but mostly self-inflicted by Defendant’s delay-causing conduct, so it weighs only slightly for Defendant | Defendant testified to severe anxiety, disability-related worsening, and loss of livelihood from restrictions | Prejudice weighed only slightly in Defendant’s favor and did not tip the balance toward dismissal |
Key Cases Cited
- State v. Garza, 146 N.M. 499, 212 P.3d 387 (2009) (articulates four-factor speedy-trial framework and guidance on weighing length/reasons/prejudice)
- State v. Spearman, 2012-NMSC-023, 283 P.3d 272 (2012) (discusses speedy-trial purpose and prejudice focus)
- State v. Montoya, 150 N.M. 415, 259 P.3d 820 (2011) (example of a short post-trigger delay weighing only slightly against the State)
- State v. Fierro, 278 P.3d 541 (N.M. Ct. App. 2012) (delay caused by defense counsel attributed to defendant)
- State v. Grissom, 106 N.M. 555, 746 P.2d 661 (1987) (delays from defendant’s motions are charged to defendant)