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321 P.3d 1127
Utah
2013
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Background

  • 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)
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Case Details

Case Name: State v. Younge
Court Name: Utah Supreme Court
Date Published: Nov 22, 2013
Citations: 321 P.3d 1127; 2013 Utah LEXIS 192; 2013 UT 71; 2013 WL 6153712; 748 Utah Adv. Rep. 51; No. 20100146
Docket Number: No. 20100146
Court Abbreviation: Utah
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    State v. Younge, 321 P.3d 1127