State v. Smith

Summary

The court affirmed Smith's convictions after rejecting his speedy-trial, prosecutorial-error, defense-evidence, charging-amendment, and cumulative-error claims. It held that the delay between trials was not presumptively prejudicial because the case's complexity, additional DNA testing, defense preparation, and pandemic-related delays made the interval reasonable. The court vacated Smith's sentence because the State failed to prove that his prior criminal-threat conviction could be included in his criminal-history score under the statute's plain language.