Vance v. State, 278 P.3d 254

Wyoming Supreme Court case involving Roman Vance's challenge to a six-and-a-half year delay between charging/arrest and trial, alleging violation of constitutional speedy-trial rights.
Arrest warrant for a 2004 felony child abuse charge never entered into NCIC, leading to undetected warrant until 2011.
Vance fled to Idaho; he was arrested there on separate charges and ultimately paroled in 2007, with Idaho release in 2010.
In 2010 the Sweetwater County Sheriff's Office discovered the missing Wyoming warrant and arrested Vance in Idaho in 2011, transporting him to Wyoming.
Vance filed a speedy-trial demand and motion to dismiss; district court denied; he entered a conditional no-contest plea one day before trial and reserved appeal on the denial.
Court reverses, concluding presumption of prejudice due to delay and failure to rebut it; remands for dismissal order

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Vance's speedy-trial rights were violated	Vance argues prolonged delay presumptively prejudicial	State contends delay neutral or negligently caused but not prejudicial	Yes, presumption of prejudice applied; district court erred; dismissal ordered

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) (presumption of prejudice when government negligence causes long delay; burden to rebut)
Wehr v. State, 841 P.2d 104 (Wy.1992) (preserve consideration of delay-related prejudice)
Berry v. State, 2004 WY 81 (Wy.2004) (negligence weighs against the government in delay analysis)
Campbell v. State, 999 P.2d 649 (Wy.2000) (adopts Barker four-factor framework in Wyoming)
Arizona v. Youngblood, 488 U.S. 51 (1988) (negligence affecting prejudice considerations)
Doggett v. United States, Doggett v. United States, 505 U.S. 647 (1992) (reiterates presumption of prejudice where delay substantial and unrebutted)
Kurtenbach v. State, 2008 WY 109 (Wy.2008) (Wyoming application of speedy-trial analysis)