State of Iowa v. Eric Lamont Harris

Summary

The Iowa Supreme Court held that under the pre‑amendment Iowa Rule of Criminal Procedure 2.33 the 45‑day speedy‑indictment clock begins at the defendant’s arrest. Because the State filed the trial information on the 46th day after Harris’s arrest, the district court erred in denying the motion to dismiss. The Court reversed and remanded for dismissal of the prosecution.