Stanley v. Watson v. State of Indiana

Summary

The court held that Indiana Criminal Rule 4(C) does not apply to retrial of a habitual-offender allegation, but that the more than six-year delay violated Watson’s constitutional right to a speedy trial. Applying the four-factor balancing framework, the court found the delay extraordinarily long, primarily attributable to the government, sufficiently asserted by Watson, and prejudicial because of his particularized anxiety. The court reversed and remanded with instructions to vacate the habitual-offender enhancement.