Taylor v. the State, 338 Ga. App. 804

Background

Taylor was convicted on multiple counts involving 15 child victims after a long pretrial history.
He appealed alleging error in Barker v. Wingo/Doggett v. United States speedy-trial balancing and in the denial of a motion to suppress evidence from his home search.
The case has a lengthy procedural history with repeated indictments, extensive discovery, and multiple continuances.
Genesis of delay included discovery issues, several continuances, and successive recusal of judges before a trial date.
Taylor asserted his Sixth Amendment right to a speedy trial; the trial court remanded for further Barker factor analysis, then denied relief.
On appeal, the Georgia Court of Appeals affirmed, holding no speedy-trial violation and affirming the denial of suppression.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Barker-Doggett speedy-trial analysis was abused	Taylor contends the delay weighed against State and the factors were misapplied.	State argues the trial court properly weighed the factors and kept deference to trial court discretion.	No abuse; factors properly weighed and kept discretion in favor of denial
Whether the denial of suppression based on warrant deficiencies was correct	Taylor argues lack of residence nexus and absence of probable cause for seized items.	State asserts nexus and probable cause supported by combination of affidavit, Attachment A, and attachments.	Affirmed; magistrate had substantial basis for probable cause and residence connection
Whether probable cause supported search of computers and electronic devices	No direct link in affidavit between Taylor and computers or digital storage.	Affidavit reasonably inferred that photos and digital devices connected to alleged acts would be found on computers.	Probable cause established; reasonable inference supported search

Key Cases Cited

Barker v. Wingo, 407 U.S. 514 (1972) (speedy trial balancing framework used in fourth-factor analysis)
State v. Alexander, 295 Ga. 154 (2014) (deferential abuse-of-discretion standard in Barker-Doggett review)
Grizzard v. State, 301 Ga. App. 613 (2009) (negligence weight in delay varies with protraction)
Milner v. State, 329 Ga. App. 654 (2014) (ten-year delay weighed benignly against State in some cases)
Moore v. State, 314 Ga. App. 219 (2012) (benign weighing of long delay due to State negligence)
Stewart v. State, 310 Ga. App. 551 (2011) (no abuse for not weighing heavily against State for five-year delay)
Buckner, 292 Ga. 390 (2013) (establishes framework for weighing when delays are lengthy)
Williams v. State, 290 Ga. 24 (2011) (discovery timing can impact mitigation of speedy-trial delay)
Williams v. State, 300 Ga. App. 797 (2009) (trial court may weigh discovery delay against defendant for speedy-trial purposes)
Boseman v. State, 263 Ga. 730 (1994) (oppressive pretrial incarceration is a major prejudice factor but not automatic)
Ward v. State, 325 Ga. App. 890 (2014) (presumed prejudice considerations when balancing)
Phan v. State, 290 Ga. 588 (2012) (presumed prejudice analysis in speedy-trial balancing)
Leopold v. State, 333 Ga. App. 777 (2015) (evidence-based prejudice considerations in balancing)
Jenkins v. State, 294 Ga. 506 (2014) (no abuse of discretion standard in Barker-Doggett review)
Sosniak v. State, 292 Ga. 35 (2012) (timing and appeal impacts on speedy-trial claims)
Hall v. State, 240 Ga. App. 356 (1999) (pretrial incarceration impacts on prejudice analysis)
Weis v. State, 287 Ga. 46 (2010) (contextual factors in speedy-trial prejudice)
Trujillo v. State, 150 N.M. 721 (2011) (common-sense nexus in warrant analysis (persuasive authority))
State v. Hunter, 282 Ga. 278 (2007) (probable cause standard for warrants deference to magistrate)