Kitchens v. State

Summary

The court vacated in part the order denying Kitchens’s motion for new trial because the trial court made a clearly erroneous finding about his assertion of the speedy-trial right and significantly misapplied the governing balancing framework. The trial court failed to calculate the full delay, distinguish presumptive prejudice from the length-of-delay factor, and assess whether the delay was uncommonly long. The case was remanded for the trial court to reconsider the speedy-trial claim using the correct facts and legal analysis.