942 N.W.2d 841
N.D.2020Background
- Joey Wayland was arrested Nov. 6, 2018, and charged with theft and possession of drug paraphernalia.
- Wayland repeatedly asserted his right to a speedy trial; counsel requested a court-ordered mental health evaluation on Jan. 3, 2019, and the court ordered the exam over Wayland’s objection.
- Trial was set for March 11, 2019; the court continued it on March 8 to April 8, 2019 (later rescheduled to May 6 and finally tried July 30, 2019).
- On March 10, 2019, while represented by counsel, Wayland sent a letter to the court saying his speedy-trial rights had passed and asking for dismissal; the letter contained no factual or legal analysis.
- The court initially did not treat the letter as a motion; after counsel withdrew, the court acknowledged the letter’s dismissal request and asked the State to respond, but no ruling was entered before trial.
- Wayland was convicted by a jury and appealed, arguing (1) violation of his speedy-trial right by the March 11 continuance and (2) violation of his right to remain silent when ordered to undergo a mental-health exam.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether continuance from Mar. 11 to Apr. 8, 2019 violated Wayland’s speedy-trial right | State: continuance did not violate constitutional speedy-trial guarantees | Wayland: continuance violated his speedy-trial rights; requested dismissal in March 10 letter | Court held no violation: de novo review found no prejudice and delay was not constitutionally violative |
| Whether ordering Wayland to submit to a court-ordered mental health exam violated his right to remain silent | State: order was proper and not challenged below | Wayland: counsel’s request and court order compelled him to submit, violating silence right | Court declined to address on appeal because issue was not raised below and Wayland did not argue obvious error |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (establishes four-factor speedy-trial balancing test)
- Doggett v. United States, 505 U.S. 647 (1992) (delays of one year or more are presumptively prejudicial)
- State v. Hamre, 924 N.W.2d 776 (2019) (applies Barker test to state and federal speedy-trial claims)
- State v. Moran, 711 N.W.2d 915 (2006) (one-year delay deemed presumptively prejudicial)
- State v. Eggleston, 940 N.W.2d 645 (2020) (issues not raised at trial are reviewed only for obvious error)
- State v. Pemberton, 930 N.W.2d 125 (2019) (defines standards for obvious-error review)
- State v. Wangstad, 917 N.W.2d 515 (2018) (obvious-error precedent cited for plain-error analysis)