Wednesday, September 12, 2012

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Speedy Trial

On April 21, 2009 an arrest warrant was issued for David Gill for a misdemeanor theft charge.  State v. Gill,  283 P.3d 236 (Kan. Ct. App. 2012).  In February of 2010 the state moved to dismiss the case in order to refile the charge as a felony theft.  A year and a half after the original warrant was issued, the State filed a felony theft charge against Gill. 

Gill then filed a motion to dismissing the felony theft charge, arguing that the period between the misdemeanor charge and felony charge caused a violation of his Sixth Amendment and statutory rights to a speedy trial. 

After considering the four balancing factors, known as the Barker factors, for determining whether the right to a speedy trial had been violated, the court determined that because only one factor, he asserted his right to a speedy trial, there was no constitutional violation present.  First, the length of delay, a ten-month period between the state’s dismissal of the misdemeanor theft charge against Gill and the filing of the felony theft charge was not considered as party of the delay.  Thus, the period of 6 months between the filing of the felony charge and trial court’s dismissal of the charge did not violate Gill’s Sixth Amendment right to speedy trial.

For more information regarding Sixth Amendment rights contact Dionne or Lindsey at 913.948.9490.

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