Watkins v. State, 315 Ga. App. 708

Watkins was arrested on Aug. 17, 2007 and indicted Aug. 28, 2007 on armed robbery-related charges.
The State re-indicted Watkins on Mar. 23, 2010 to add aggravated assault with deadly weapon and two firearm-possession counts.
Watkins moved to dismiss on Jul. 30, 2010; the trial court denied the motion on Aug. 9, 2011, nearly four years after arrest.
The almost four-year delay is conceded to be presumptively prejudicial, triggering Barker analysis.
The trial court failed to make the Barker v. Wingo findings needed to assess the speedy-trial claim, and did not adequately explain causation, justification, or prejudice.
The appellate court vacates the judgment and remands for entry of proper Barker-based findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the denial of the speedy-trial motion an abuse of discretion?	Watkins argues the court failed to apply Barker properly.	State contends the delay weighed in Watkins's favor or was balanced.	Yes; remand for proper Barker findings required.
Did the trial court make sufficient Barker findings and properly balance factors?	Watkins asserts missing/insufficient findings on delay reasons, assertion, prejudice.	State asserts findings were adequate to support denial.	No; remand for explicit Barker-based findings required.
Is the four-year delay presumptively prejudicial and properly attributed?	Watkins contends delay is lengthy and prejudicial.	State argues some delay attributed to Watkins; but needs explicit analysis.	Insufficient to determine balancing; remand necessary.

Barker v. United States, 407 U.S. 514 (1972) (speedy-trial balancing framework)
Higgenbottom v. State, 288 Ga. 429 (2011) (requires explicit Barker findings by trial court)
State v. Porter, 288 Ga. 524 (2011) (adopts Barker framework in Georgia context; emphasizes weighing factors)
Pickett v. State, 288 Ga. 674 (2011) (limits appellate weighing; requires proper trial-court analysis)