State v. Ochoa

Summary

The New Mexico Supreme Court reversed the Court of Appeals and reinstated John Eric Ochoa’s convictions, holding that his Sixth Amendment right to a speedy trial was not violated. The Court applied the Barker v. Wingo four‑factor test and found that the length of delay, the reasons for delay, and the defendant’s assertion of the right did not outweigh the prejudice factor. Consequently, the appellate court’s bright‑line rule on pre‑trial incarceration was rejected.