Teasley v. State
307 Ga. App. 153
| Ga. Ct. App. | 2010Background
- Teasleys were indicted August 31, 2006 for one count of cruelty to children involving their three-week-old child.
- Arraignment occurred October 5, 2006; Elizabeth demanded a speedy trial in October 2006 and again in March 2007, but no statutory demand under OCGA § 17-7-170 was filed.
- Defense counsel changes and court-ordered continuances occurred from 2007 to 2009, including conflicts, replacement counsel, and multiple continuances due to medical records and scheduling issues.
- In October 2009 the Teasleys moved for discharge and acquittal based on a violation of the right to a speedy trial; hearing occurred November 2, 2009, about three years and two months after indictment.
- The trial court denied the motion; on appeal, the Georgia Court of Appeals partially reversed, granting discharge and acquittal for Elizabeth and affirming Jerry’s conviction, and remanded with instruction.
- Court held the delay was presumptively prejudicial and used Barker v. Wingo analysis; several errors by the trial court led to abuse of discretion on Elizabeth’s discharge motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the pretrial delay was presumptively prejudicial | Teasleys claim delay exceeded threshold to trigger review. | State contends delay was not presumptively prejudicial or resolved by other factors. | Delay was presumptively prejudicial. |
| Whether the four Barker factors support a speedy-trial violation | Delay excessive; State blame; asserting right; prejudice shown, especially Elizabeth. | Delay attributable to defenses, continuances, and logistical issues; some prejudice claimed but not all. | Factors weigh against the State; overall violation found for Elizabeth; not clearly for Jerry. |
| Whether failure to file a statutory speedy-trial demand defeats the claim | Constitutional right not dependent on statutory demand; due-course assertion suffices. | Statutory demand or failure thereof can influence consideration. | Statutory demand not required; due-course assertion governs. |
| Whether the trial court erred by considering victim's rights and alleged unseriousness of the delay | Victim's interests do not justify neglecting constitutional rights; delay harmed Elizabeth. | Balancing victim's rights against defendant's rights could justify some delay in this case. | Court erred by balancing victim’s rights against defendant; no such justification for lengthy delay. |
Key Cases Cited
- Ruffin v. State, 284 Ga. 52 (2008) (two-stage speedy-trial analysis; presumptive prejudice threshold)
- Barker v. Wingo, 407 U.S. 514 (1972) (four-factor balancing framework)
- Doggett v. United States, 505 U.S. 647 (1992) (uncommonly long delay; prejudice and diligence considerations)
- Layman v. State, 284 Ga. 83 (2008) (balancing factors; context-sensitive application)
- Brannen v. State, 274 Ga. 454 (2001) (negligence in delays; state responsibility when no delay reason shown)
- Hayes v. State, 298 Ga. App. 338 (2009) (statutory demand not prerequisite for speedy-trial claim)