William Ray Grimes v. State of Indiana

Summary

The Indiana Supreme Court held that Grimes was entitled to discharge under Criminal Rule 4 because he timely objected to the congestion-based continuance, made a prima facie showing that the court had calendar availability, and the trial court failed to explain its congestion finding. The Court also held that the State waived its alternative emergency-based justification by failing to raise it below. The Court reversed and remanded with instructions to discharge Grimes.