State v. Stops
2013 MT 131
| Mont. | 2013Background
- Arrest of Stops on April 9, 2009 for DUI-related offenses; driver stopped, officers observed impairment and arrested him.
- Arraignment on April 14, 2009 on three charges: DUI felonies, resisting arrest, and operating without proof of insurance, with restitution request for patrol car damage.
- Stops notified he did not qualify for public defender; appeared pro se but then obtained counsel. Several continuances and waivers of speedy trial rights were entered as Stops sought counsel.
- Continued trial dates: August 25, 2009; December 16, 2009; April 29, 2010; November 22, 2010; February 9, 2011; culminating in a verdict on April 19–21, 2011.
- Stops filed a motion to dismiss (speedy trial violation) on January 10, 2011; briefing followed through February 2011.
- District Court denied the motion to dismiss on April 7, 2011 and trial proceeded, resulting in Stops’ conviction and sentence
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court provided sufficient findings on the Ariegwe factors | Stops argues findings were cursory and insufficient | State contends findings, though not perfect, enable review and correct application of Ariegwe | No error; findings adequate for review |
| Whether Stops’ speedy-trial rights were violated under Ariegwe balancing | Delay prejudiced Stops; total delay 740 days; State failed to justify all delays | Delay weighed against Stops; most delays attributable to Stops or institutional/valid reasons; no prejudice shown | Not violated; balancing favors State |
Key Cases Cited
- State v. Couture, 240 P.3d 987 (2010 MT 201) (revised framework; four-factor balancing; de novo review of law)
- State v. Ariegwe, 167 P.3d 815 (2007 MT 204) (four-factor test; necessity of findings; detailed balancing)
- State v. Billman, 194 P.3d 58 (2008 MT 326) (institutional delay; valid reasons; delays weighed accordingly)
- State v. Sartain, 241 P.3d 1032 (2010 MT 213) (prejudice considerations; threshold 200 days; evaluation of factors)
- State v. Houghton, 234 P.3d 904 (2010 MT 145) (clarifies de novo assessment of speedy-trial issues)