People v. Tyson

Summary

The Court of Appeals held that the 14-month period between the alleged assault and indictment did not violate defendant's constitutional right to prompt prosecution after balancing the five relevant factors. Although the prosecution failed to explain a nine-month portion of the delay, the overall period, lack of defense prejudice, and other circumstances did not require dismissal, so the indictment was reinstated and the case remitted. The opinion text includes a dissent arguing that the unexplained delay violated due process, but no separate-opinion record was provided.