State of Alaska, Petitioner v. Sean Wright, Respondent

Summary

The court held that Alaska’s constitutional speedy-trial right begins when the State files a criminal information, even before arrest or indictment. Applying the four-factor balancing test, it concluded that Wright’s flight from Alaska and efforts to remain difficult to locate bore primary responsibility for the nearly five-year delay, so the superior court correctly denied dismissal. Justice Bolger concurred in the result but would apply due process rather than speedy-trial analysis before arrest or indictment, and Justice Carney concurred on attachment but would remand for reconsideration of responsibility for the delay.