190 Washington opinions name it 2 courts 1976–2026 17 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Barker v. Wingogreen2 sentences2024Taffy Gober testified, similar to Hicks’s delay and/or prejudice suffered by the defendant will have to be greater than that in cases where recklessness or intentional government conduct is alleged.” Id. 2 Barker involved a speedy trial claim, but the Court cited Marion in reasoning that more “neutral reason[s] [for delay] such as negligence or overcrowded courts should be weighted less heavily” against the government than delays made in “deliberate attempt . . . to hamper the defense.” 407 U.S. at 531 . 17 State v. Stearns, No. 101502-0 statement, that she saw Williams with another man, ident 2020Ed. 2d 520 (1992), and any “inquiry into a speedy trial claim 17 No. 78868-0-I/18 necessitates a functional analysis of the right in the particular context of the case.” Barker v. Wingo, 407 U.S. 514, 522 , 92 S. Ct. 2182 , 33 L. | 5 | 25 |
Doggett v. United Statesgreen2 sentences2025To trigger a complete speedy-trial analysis, the defendant must show that the length of the delay “ ‘crossed the threshold dividing ordinary from presumptively prejudicial delay.’ ” Id. at 827 (internal quotation marks omitted) (quoting Doggett v. United States, 505 U.S. 647, 651 , 112 S. Ct. 2686 , 120 L. 2025To trigger a complete speedy-trial analysis, the defendant must show that the length of the delay “ ‘crossed the threshold dividing ordinary from presumptively prejudicial delay.’ ” Id. at 827 (internal quotation marks omitted) (quoting Doggett v. United States, 505 U.S. 647, 651 , 112 S. Ct. 2686 , 120 L. | 4 | 14 |
State v. Olliviergreen2 sentences2025To trigger a complete speedy-trial analysis, the defendant must show that the length of the delay “ ‘crossed the threshold dividing ordinary from presumptively prejudicial delay.’ ” Id. at 827 (internal quotation marks omitted) (quoting Doggett v. United States, 505 U.S. 647, 651 , 112 S. Ct. 2686 , 120 L. 2024“In order to trigger the speedy-trial analysis, ‘an accused must allege that the 10 84803-8-I/11 interval between accusation and trial has crossed the threshold dividing ordinary from presumptively prejudicial delay because by definition, the accused cannot complain that the government has denied him a speedy trial if it has, in fact, prosecuted his case with customary promptness.’” Ollivier, 178 Wn.2d at 827 (internal quotation marks omitted) (quoting Doggett v. United States, 505 U.S. 647, 651-52 , 112 S. Ct. 2686 , 120 L. | 4 | 14 |
State v. Whitegreen2 sentences2003See State v. White, 23 Wn. 2003See State v. White, 23 Wash.App. 438, 441 , 597 P.2d 420 , aff'd, 94 Wash.2d 498 , 617 P.2d 998 (1980). | 4 | 4 |
State v. Edwardsgreen2 sentences2018The rule places no qualifications on the court's discretion, yet our Supreme Court has recognized that some reasons for a State motion to dismiss may be "inappropriate." In State v. Edwards, 94 Wn.2d 208,214 , 616 P.2d 620 (1980), for example, the Court stated that "[a]n attempt to avoid the speedy trial rule would be an inappropriate reason for dismissal." The few reported Washington cases in which a ruling on a prosecutor's motion to dismiss was appealed involve defense objections that dismissal was requested for an inappropriate reason. 2018The rule places no qualifications on the court's discretion, yet our Supreme Court has recognized that some reasons for a State motion to dismiss may be "inappropriate." In State v. Edwards, 94 Wn.2d 208,214 , 616 P.2d 620 (1980), for example, the Court stated that "[a]n attempt to avoid the speedy trial rule would be an inappropriate reason for dismissal." The few reported Washington cases in which a ruling on a prosecutor's motion to dismiss was appealed involve defense objections that dismissal was requested for an inappropriate reason. | 3 | 12 |
State v. Carsongreen2 sentences2018App. 378 , 884 P.2d 1356 (1994), and State v. Carson, 128 Wn.2d 805 , 912 P.2d 1016 (1996) for the proposition that defense counsel sometimes holds the duty to alert the court of the potential for a speedy trial violation. 2003App. 337 , 848 P.2d 1276 (1993) (holding that the trial court did not abuse its discretion in granting a continuance under the speedy trial rule in order to allow another case to go to trial); State v. Carson, 128 Wn.2d 805 , 912 P.2d 1016 (1996) (holding that the unavailability of counsel due to trial schedules justifies an extension). | 3 | 6 |
State v. Carsongreen2 sentences2018App. 378 , 884 P.2d 1356 (1994), and State v. Carson, 128 Wn.2d 805 , 912 P.2d 1016 (1996) for the proposition that defense counsel sometimes holds the duty to alert the court of the potential for a speedy trial violation. 2003App. 337 , 848 P.2d 1276 (1993) (holding that the trial court did not abuse its discretion in granting a continuance under the speedy trial rule in order to allow another case to go to trial); State v. Carson, 128 Wn.2d 805 , 912 P.2d 1016 (1996) (holding that the unavailability of counsel due to trial schedules justifies an extension). | 3 | 5 |
State v. MacKgreen2 sentences2014No. 69811-7-1/5 available courtrooms and judges, this failure may result in a violation of the speedy trial rule.10 In the context of involuntary treatment act proceedings, the leading case analyzing "good cause" under the statute is In re Detention of Kirby.11 There, this court looked to criminal cases for guidance and acknowledged the general rule that docket congestion does not generally constitute good cause.12 But this court also stated, "Where the circumstances attending the request are anomalous rather than typical of the operation of the administration of justice, granting a continuanc 1995Por example, in interpreting "good cause” in the context of the speedy trial rule, this court stated that "[s]elf-created hardship is not an excuse for violating mandatory rules.” State v. Mack, 89 Wn.2d 788, 794 , 576 P.2d 44 (1978). | 2 | 10 |
United States v. Jordangreen2 sentences2008Fitzgerald v. Jordan, 747 F.2d 1120, 1127 (7th Cir. 1984) (holding that a delay of 8 months is enough to provoke a speedy trial inquiry); Smith v. State, 550 So. 2d 406, 408 (Miss. 1989) (“While there are some exceptions to the rule, ‘it may generally be said that any delay of eight months or longer is presumptively prejudicial.’ ”) (internal quotation marks omitted) (quoting 2 Wayne R. 2008Fitzgerald v. Jordan, 747 F.2d 1120 , 1127 (7th Cir.1984) (holding that a delay of eight months is enough to provoke a speedy trial inquiry); Smith v. State, 550 So.2d 406, 408 (Miss. 1989) ("While there are some exceptions to the rule, `it may generally be said that any delay of eight months or longer is presumptively prejudicial.'") (internal quotation marks omitted) (quoting 2 WAYNE R. | 2 | 3 |
State v. Rapergreen2 sentences2001In addition, a motion for continuance under CrR 3.3(h)(2) must be filed "on or before the date set for trial or the last day of any continuance or extension," whereas an extension under CrR 3.3(d)(8) is allowed "even if the time for trial has expired." See State v. Raper, 47 Wash.App. 530, 534-37 , 736 P.2d 680 (1987). *652 Extensions under CrR 3.3(d)(8) and continuances under (h)(2) impact the 60- or 90-day requirement of the speedy trial rule in different ways. 2001In addition, a motion for continuance under CrR 3.3(h)(2) must be filed "on or before the date set for trial or the last day of any continuance or extension," whereas an extension under CrR 3.3(d)(8) is allowed "even if the time for trial has expired." See State v. Raper, 47 Wash.App. 530, 534-37 , 736 P.2d 680 (1987). *652 Extensions under CrR 3.3(d)(8) and continuances under (h)(2) impact the 60- or 90-day requirement of the speedy trial rule in different ways. | 2 | 3 |
| State v. Whitegreen | 2 | 2 |
| In Re the Personal Restraint of Phelangreen | 2 | 2 |
| United States v. Raymond Woodsgreen | 2 | 2 |
| State v. Perrettgreen | 2 | 2 |
| Albert George Fouts v. United States of America, Virgil Summers v. United Statesgreen | 2 | 2 |
| United States v. Brian S. Grimmondgreen | 2 | 2 |
| Smith v. Stategreen | 2 | 2 |
| State v. Parmelegreen | 2 | 2 |
State v. Strikergreen2 sentences2000Jones were dismissed for violation of the speedy trial rule under CrR 3.3 and State v. Striker, 87 Wash.2d 870 , 557 P.2d 847 (1976). 2000Jones were dismissed for violation of the speedy trial rule under CrR 3.3 and State v. Striker, 87 Wash.2d 870 , 557 P.2d 847 (1976). | 1 | 14 |
State v. Iniguezgreen2 sentences2025Under Barker, a defendant who alleges a speedy trial violation must first show the delay “crossed a line from ordinary to presumptively prejudicial.” Iniguez, 167 Wn.2d at 283 . 2020Balancing each of the above factors, we find that the delay under the totality of the circumstances was not a speedy trial violation of constitutional magnitude that justifies the extreme remedy of dismissal of the charges with prejudice. 29 Iniguez, 167 Wn.2d at 294 . 30 Id. at 295 . 31 Id. 14 No. 78412-9-1/15 b. | 1 | 11 |
State v. Adamskigreen2 sentences2006But as our Supreme Court has observed in another context, if “administration of justice” can be invoked at any time to grant a continuance, then “there is little point in having the speedy trial rule at all.” State v. Adamski, 111 Wn.2d 574, 580 , 761 P.2d 621 (1988). 2006But as our Supreme Court has observed in another context, if “administration of justice” can be invoked at any time to grant a continuance, then “there is little point in having the speedy trial rule at all.” State v. Adamski, 111 Wn.2d 574, 580 , 761 P.2d 621 (1988). | 1 | 4 |
State v. Becerragreen2 sentences1996App. 202, 206 , 831 P.2d 781 (1992) (criminal defendant waived speedy trial objection by not raising issue at a time when the trial court could take action to avoid violation of the speedy trial rule); State v. Austin, 59 Wn. 1996Not timely asserting the defendant's speedy trial right because of a failure to discover easily ascertainable facts constituted a waiver); State v. Becerra, 66 Wash.App. 202, 206 , 831 P.2d 781 (1992) (criminal defendant waived speedy trial objection by not raising issue at a time when the trial court could take action to avoid violation of the speedy trial rule); State v. Austin, 59 Wash.App. 186 , 796 P.2d 746 (1990) (criminal defendant waived right to speedy trial by not raising the issue until after it was too late to commence the trial within the speedy trial period); see also State v. Ra | 1 | 3 |
| State v. Biblegreen | 1 | 2 |
| State v. Williamsgreen | 1 | 2 |
| State v. Angulogreen | 1 | 2 |
| Butts v. Hellergreen | 1 | 2 |
| State v. Georgegreen | 1 | 1 |
| State v. Georgegreen | 1 | 1 |
| United States v. Fernandesgreen | 1 | 1 |
| United States v. Jerry Lee Howardgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Carlyle
green
2 sentences2014Id. at 35 . 2013State v. Carlyle, 84 Wn. | 6 | 2008–2014 |
State v. Kenyon
green
2 sentences2019“We review an alleged violation of the speedy trial rule de novo.” State v. Kenyon, 167 Wn.2d 130, 135 , 216 P.3d 1024 (2009). 2019App. at 811 . 'We review an alleged violation of the speedy trial rule de novo." State v. Kenyon, 167 Wn.2d 130, 135 , 216 P.3d 1024 (2009). | 5 | 2016–2020 |
State v. Kenyon
green
2 sentences2019“We review an alleged violation of the speedy trial rule de novo.” State v. Kenyon, 167 Wn.2d 130, 135 , 216 P.3d 1024 (2009). 2019App. at 811 . 'We review an alleged violation of the speedy trial rule de novo." State v. Kenyon, 167 Wn.2d 130, 135 , 216 P.3d 1024 (2009). | 5 | 2016–2020 |
United States v. Loud Hawk
green
2 sentences2014No. 70638-1-1/3 Where a defendant claims the denial of these rights, our review is de novo.4 The defendant's constitutional rights to a speedy trial attach when a charge is filed or an arrest is made, whichever occurs first.5 Some pretrial delay is often "inevitable and wholly justifiable,"6 and any "inquiry into a speedy trial claim necessitates a functional analysis of the right in the particular context of the case."7 Accordingly, we utilize "an ad hoc balancing test that examines the conduct of both the State and the defendant to determine whether speedy trial rights have been denied."8 Th 2014No. 70638-1-1/3 Where a defendant claims the denial of these rights, our review is de novo.4 The defendant's constitutional rights to a speedy trial attach when a charge is filed or an arrest is made, whichever occurs first.5 Some pretrial delay is often "inevitable and wholly justifiable,"6 and any "inquiry into a speedy trial claim necessitates a functional analysis of the right in the particular context of the case."7 Accordingly, we utilize "an ad hoc balancing test that examines the conduct of both the State and the defendant to determine whether speedy trial rights have been denied."8 Th | 5 | 1988–2014 |
State v. Greenwood
green
2 sentences2003CrR 3.3(c)(1); State v. Greenwood, 120 Wn.2d 585, 589 , 845 P.2d 971 (1993); State v. Jones, 79 Wn. 2003CrR 3.3(c)(1); State v. Greenwood, 120 Wn.2d 585, 589 , 845 P.2d 971 (1993); State v. Jones, 79 Wn. | 5 | 1998–2003 |
State v. Swenson
green
2 sentences2014State v. Swenson, 150 Wn.2d 181, 186 , 75 P.3d 513 (2003). 2014State v. Swenson, 150 Wn.2d 181, 186 , 75 P.3d 513 (2003). | 4 | 2004–2014 |
State v. Campbell
green
2 sentences2014This court will not consider an 4 Report of Proceedings (RP) (Apr. 16, 2012) at 9. 5]d\ 6 id, at 8. 7 Id at 9 (citing State v. Campbell, 103 Wn.2d 1 , 691 P.2d 929 (1984)). 2014This court will not consider an 4 Report of Proceedings (RP) (Apr. 16, 2012) at 9. 5]d\ 6 id, at 8. 7 Id at 9 (citing State v. Campbell, 103 Wn.2d 1 , 691 P.2d 929 (1984)). | 4 | 1996–2014 |
State v. Flinn
green
2 sentences2009While CrR 3.3 allows some "flexibility in avoiding the harsh remedy of dismissal with prejudice," State v. Flinn, 154 Wash.2d 193 , 199 n. 1, 110 P.3d 748 (2005), allowing continuances beyond the 60 day limit based on another trial or a judge's vacation would render the speedy trial rule virtually meaningless. ¶ 31 I respectfully concur. 2009While CrR 3.3 allows some “flexibility in avoiding the harsh remedy of dismissal with prejudice,” State v. Flinn, 154 Wn.2d 193 , 199 n.1, 110 P.3d 748 (2005), allowing continuances beyond the 60 day limit based on another trial or a judge’s vacation would render the speedy trial rule virtually meaningless. ¶32 I respectfully concur. | 4 | 2008–2009 |
State v. Hudson
green
2 sentences2006Anderson, 121 Wn.2d at 864 ; State v. Hudson, 130 Wn.2d 48, 56 , 921 P.2d 538 (1996). ¶12 CrR 3.3(b) guarantees Washington defendants a right to speedy trial within a specific time frame. 2006Anderson, 121 Wash.2d at 864 , 855 P.2d 671 ; State v. Hudson, 130 Wash.2d 48, 56 , 921 P.2d 538 (1996). ¶ 12 CrR 3.3(b) guarantees Washington defendants a right to speedy trial within a specific time frame. | 4 | 2000–2006 |
State v. Hudson
green
2 sentences2006Anderson, 121 Wn.2d at 864 ; State v. Hudson, 130 Wn.2d 48, 56 , 921 P.2d 538 (1996). ¶12 CrR 3.3(b) guarantees Washington defendants a right to speedy trial within a specific time frame. 2006Anderson, 121 Wash.2d at 864 , 855 P.2d 671 ; State v. Hudson, 130 Wash.2d 48, 56 , 921 P.2d 538 (1996). ¶ 12 CrR 3.3(b) guarantees Washington defendants a right to speedy trial within a specific time frame. | 4 | 2000–2006 |
State v. Ralph Vernon G.
green
2 sentences2004State v. Adamski, 111 Wn.2d 574, 582, 761 P.2d 621 (1988); Swenson, 150 Wn.2d at 186-87 ; State v. Ralph G., 90 Wn. 2004State v. Adamski, 111 Wash.2d 574, 582 , 761 P.2d 621 (1988); Swenson, 150 Wash.2d at 186-87 , 75 P.3d 513 ; State v. Ralph G., 90 Wash.App. 16, 20-21 , 950 P.2d 971 (1998). | 4 | 1999–2004 |
State v. Malone
green
2 sentences2003State v. Malone, 72 Wn. 2003State v. Malone, 72 Wash.App. 429, 433 , 864 P.2d 990 (1994). | 4 | 1996–2003 |
State v. Williams
green
2 sentences2001See State v. Edwards, 94 Wn.2d 208 , 616 P.2d 620 (1980); State v. Williams, 85 Wn.2d 29 , 530 P.2d 225 (1975). 2001See State v. Edwards, 94 Wn.2d 208 , 616 P.2d 620 (1980); State v. Williams, 85 Wn.2d 29 , 530 P.2d 225 (1975). | 4 | 1977–2001 |
State v. Fladebo
green
2 sentences1996In an unpublished opinion, the Court of Appeals cited State v. Fladebo, 113 Wn.2d 388 , 779 P.2d 707 (1989) and held the speedy trial rule did not apply to Defendant’s situation. 1996In an unpublished opinion, the Court of Appeals cited State v. Fladebo, 113 Wn.2d 388 , 779 P.2d 707 (1989) and held the speedy trial rule did not apply to Defendant’s situation. | 4 | 1990–1999 |
State v. Swenson
green
2 sentences2014State v. Swenson, 150 Wn.2d 181, 186 , 75 P.3d 513 (2003). 2014State v. Swenson, 150 Wn.2d 181, 186 , 75 P.3d 513 (2003). | 3 | 2004–2014 |
State v. Flinn
green
2 sentences2009While CrR 3.3 allows some "flexibility in avoiding the harsh remedy of dismissal with prejudice," State v. Flinn, 154 Wash.2d 193 , 199 n. 1, 110 P.3d 748 (2005), allowing continuances beyond the 60 day limit based on another trial or a judge's vacation would render the speedy trial rule virtually meaningless. ¶ 31 I respectfully concur. 2009While CrR 3.3 allows some “flexibility in avoiding the harsh remedy of dismissal with prejudice,” State v. Flinn, 154 Wn.2d 193 , 199 n.1, 110 P.3d 748 (2005), allowing continuances beyond the 60 day limit based on another trial or a judge’s vacation would render the speedy trial rule virtually meaningless. ¶32 I respectfully concur. | 3 | 2008–2009 |
| United States v. Ewell green | 3 | 1979–1986 |
| State v. Lackey neutral | 2 | 2024–2026 |
| State v. Iniguez green | 2 | 2014–2025 |
| State v. Shemesh green | 2 | 2023–2024 |
| State v. Jenkins green | 2 | 1996–2018 |
| In the Matter of Detention of Kirby green | 2 | 1995–2014 |
| State v. Raschka neutral | 2 | 2012–2013 |
| State v. Raschka green | 2 | 2012–2013 |
| State v. Alter green | 2 | 2009–2009 |
| United States of America Ex Rel. Louis Von Cseh v. Edward M. Fay, Warden of Greenhaven State Prison, Stormville, New York green | 2 | 2009–2009 |
| State v. Ramos green | 2 | 2006–2006 |
| State v. Ramos green | 2 | 2006–2006 |
| State v. Anderson green | 2 | 2006–2006 |
| State v. Branstetter green | 2 | 2004–2004 |
| State v. McCormack green | 2 | 2004–2004 |
| State v. Wake green | 2 | 2003–2003 |
| State v. Cockrell green | 2 | 2003–2003 |
| State v. Thomas green | 2 | 2003–2003 |
| State v. Earl neutral | 2 | 2001–2001 |
| State v. Wilks neutral | 2 | 1997–1999 |
| State v. Greenwood green | 2 | 1997–1998 |
| State v. Austin green | 2 | 1996–1996 |
| State v. Cintron-Cartegena neutral | 2 | 1996–1996 |
| State v. Lawley green | 2 | 1983–1991 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.