State of Alaska, Petitioner v. Sean Wright, Respondent

Summary

The court held that Alaska’s constitutional speedy-trial period begins when the State files a criminal information, even if the defendant has not yet been arrested or indicted. Applying the four-factor balancing test, it affirmed the superior court’s determination that Wright bore primary responsibility for the nearly five-year pre-arrest delay because he left Alaska and moved among several states after learning he was under investigation, while the State’s negligence was secondary. The court therefore reversed the court of appeals and remanded with directions to affirm the superior court. Justice Bolger, concurring, would have applied due process rather than speedy-trial analysis before arrest or indictment, and Justice Carney, concurring in part and dissenting in part, would have found the State primarily responsible for the pre-arrest delay and remanded for further findings.