Price v. State

Summary

The court held that the trial court materially misapplied the constitutional speedy-trial framework by conflating presumptive prejudice with the length-of-delay factor, improperly neutralizing State-attributable delay with unsupported defense counsel absences, and disregarding the defendant’s noncompliant speedy-trial demand. Because the appellate court could not determine that the trial court would necessarily reach the same result under the correct analysis, it vacated the speedy-trial ruling in part and remanded for reconsideration. The trial court’s prejudice analysis was upheld and need not be revisited.