321 P.3d 1127
Utah2013Background
- R.C. was attacked and sexually assaulted in November 1996; DNA profile of the attacker was added to CODIS with no initial match.
- In March 2000, the State filed an information charging John Doe (unknown male) with two counts of aggravated sexual assault and one count of robbery, identified by DNA profile.
- In 2002 a CODIS match identified Donald E. Younge Jr.; Utah collected his blood in Illinois and the DNA profile matched the John Doe information.
- September 2002, the State amended the information naming Younge; extradition to Utah later followed; charges remained pending in Illinois.
- Younge was extradited to Utah in 2009; trial began December 2009; he challenged statute-of-limitations and speedy-trial rights, which the court addressed and rejected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was prosecution commenced within the statute of limitations? | Younge argued the first information was invalid and the amended information was not timely | State contends the first information was valid and tolling/identity issues were resolved timely | Yes; first information valid; prosecution commenced within limitations |
| Did the delay violate Younge's right to a speedy trial under the Sixth Amendment? | Delay was extraordinary and prejudicial to defense | Delay largely outside State control; Barker factors weigh against due process violation | No; speedy-trial rights were not violated |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (1972) (four-factor balancing test for speedy-trial claims)
- Doggett v. United States, 505 U.S. 647 (1992) (delay as a trigger; factors interact in balancing test)
- United States v. Grimmond, 137 F.3d 823 (4th Cir. 1998) (speedy-trial analysis; delays and prejudice considerations)
- State v. Ossana, 739 P.2d 628 (Utah 1987) (Utah speedy-trial considerations and balancing)
- State v. Renzo, 443 P.2d 392 (Utah 1968) (state-level speedy-trial framework and context)
