State v. Thompson-Jacobson, 508 P.3d 604

In March 2006 Utah filed an information charging Sean Glen Thompson‑Jacobson with two counts of aggravated sexual abuse of a child and issued an arrest warrant authorizing extradition.
At the time Utah filed charges it knew Thompson‑Jacobson was incarcerated in Nevada (convicted there in 2006 and imprisoned until April 2013).
Utah did not lodge an Interstate Agreement on Detainers detainer or seek extradition while he served his Nevada sentence; no Utah action was taken for nearly seven years.
In July 2009 Thompson‑Jacobson (pro se) requested court forms; he received no substantive response. After release from Nevada custody he refused to waive extradition; Utah began extradition in May 2013 and he was brought to Utah in August/September 2013.
He moved to dismiss for violation of the Sixth Amendment speedy‑trial right; the district court denied the motion, he was tried and convicted, and on appeal the Utah Court of Appeals found the seven‑plus year delay—much of it attributable to Utah’s inaction—violated his right and vacated the convictions, remanding with instructions to dismiss.
The court emphasized relevant defendant facts: he lacked counsel while incarcerated, had diagnosed mental‑health and cognitive limitations, and thus had diminished ability to assert the speedy‑trial right while imprisoned in Nevada.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Utah violated the Sixth Amendment speedy‑trial right by delaying prosecution ~7.5 years	State: delay caused by defendant's Nevada incarceration; defendant failed to assert right; any delay was not deliberate and prejudice is minimal	Thompson‑Jacobson: State negligently failed to use available means (detainer/extradition) to secure his presence; long delay caused presumptive and actual prejudice and he lacked ability to assert the right while incarcerated and without counsel	Court: Held violative of the Sixth Amendment. Lengthy delay and State’s negligence (failure to seek detainer/extradition) weighed for defendant; asserted‑right factor weak but limited by his lack of counsel/competence; prejudice presumed. Convictions vacated and charges to be dismissed.

Barker v. Wingo, 407 U.S. 514 (1972) (establishes four‑factor balancing test for speedy‑trial claims)
Doggett v. United States, 505 U.S. 647 (1992) (presumption of prejudice increases with excessive delay)
Strunk v. United States, 412 U.S. 434 (1973) (dismissal required when delay violates speedy‑trial right)
Smith v. Hooey, 393 U.S. 374 (1969) (incarceration in another jurisdiction markedly increases risk that delay will impair defense)
Dickey v. Florida, 398 U.S. 30 (1970) (prompt inquiry into charges is a fundamental duty of the charging authority)
State v. Younge, 321 P.3d 1127 (Utah 2013) (length of delay as triggering mechanism and context for speedy‑trial inquiry)