Nelson v. State

Summary

The Court vacated the denial of Nelson’s motion to dismiss on constitutional speedy-trial grounds and remanded for the trial court to reconsider the motion under the proper factual and legal framework. The trial court failed to separately weigh the length-of-delay factor, relied on clearly erroneous findings concerning responsibility for delay and the timing of Nelson’s assertion, and improperly disregarded evidence relevant to oppressive pretrial incarceration and anxiety. The trial court was not compelled to deny the motion after correcting those errors, so appellate reweighing was improper.