speedy trial violation (Idaho) · Go Syfert
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speedy trial violation in Idaho

29 Idaho opinions name it 2 courts 1963–2025 10 in the last five years

The cases below were cited by Idaho 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.

Followed or applied (19)

CaseFollowedCited
Barker v. Wingogreen
scotus · 1972 · cited in 9 Idaho opinions naming this issue, 1994–2024
2 sentences

2024These factors are similar but not identical to the Sixth Amendment right to a speedy trial analysis outlined in Barker v. Wingo, 407 U.S. 514 (1972).

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

49
State v. Younggreen
idaho · 2001 · cited in 6 Idaho opinions naming this issue, 2011–2025
2 sentences

2024Moreover, we have previously held that a defendant’s generalized anxiety regarding the outcome of his case is insufficient by itself to support a speedy trial violation in State v. Young, 136 Idaho 113, 118 , 29 P.3d 949, 954 (2001).

2024Moreover, we have previously held that a defendant’s generalized anxiety regarding the outcome of his case is insufficient by itself to support a speedy trial violation in State v. Young, 136 Idaho 113, 118 , 29 P.3d 949, 954 (2001).

36
State v. Craig C. Risdongreen
idahoctapp · 2012 · cited in 3 Idaho opinions naming this issue, 2023–2024
2 sentences

2024State v. Risdon, 154 Idaho 244, 252 , 296 P.3d 1091, 1099 (Ct. App. 2012).

2024State v. Risdon, 154 Idaho 244, 252 , 296 P.3d 1091, 1099 (Ct. App. 2012).

33
State v. Rodriquez-Perezgreen
idahoctapp · 1996 · cited in 3 Idaho opinions naming this issue, 2010–2014
2 sentences

2014State v. Rodriquez- Perez, 129 Idaho 29, 34 , 921 P.2d 206, 211 (Ct. App. 1996) (citing Barker v. Wingo, 407 U.S. 514, 530 (1972)).

2014State v. Rodriquez- Perez, 129 Idaho 29, 34 , 921 P.2d 206, 211 (Ct. App. 1996) (citing Barker v. Wingo, 407 U.S. 514, 530 (1972)).

23
State v. Lankfordgreen
idaho · 2023 · cited in 2 Idaho opinions naming this issue, 2024–2024
2 sentences

2024Before we begin with the application of the speedy trial rule to this case, we note that during oral argument the State expressed disagreement with this Court’s recent holding in State v. Lankford, 172 Idaho 548 , ____, 535 P.3d 172, 184 (2023), arguing that the right to a speedy trial, once waived, is not automatically renewed on remand.

2024Before we begin with the application of the speedy trial rule to this case, we note that during oral argument the State expressed disagreement with this Court’s recent holding in State v. Lankford, 172 Idaho 548 , ____, 535 P.3d 172, 184 (2023), arguing that the right to a speedy trial, once waived, is not automatically renewed on remand.

22
State v. Davisgreen
idahoctapp · 2005 · cited in 2 Idaho opinions naming this issue, 2023–2024
2 sentences

2024See Davis, 141 Idaho at 839 , 118 P.3d at 171 (noting defendant’s acquiescence in delay “in hopes” that a motion to reconsider would be granted weighed against finding a speedy trial violation).

2024See Davis, 141 Idaho at 839 , 118 P.3d at 171 (noting defendant’s acquiescence in delay “in hopes” that a motion to reconsider would be granted weighed against finding a speedy trial violation).

22
State v. Ishgreen
idaho · 2024 · cited in 2 Idaho opinions naming this issue, 2024–2024
2 sentences

2024See id. (holding that “delays attributable to this Court’s emergency orders” were justified because “there were dire circumstances presenting ‘a more pressing public need’: protecting the health of all trial participants during a global pandemic.” (quoting Barker, 407 U.S. at 537 (White, J., concurring))).

2024See id. (holding that “delays attributable to this Court’s emergency orders” were justified because “there were dire circumstances presenting ‘a more pressing public need’: protecting the health of all trial participants during a global pandemic.” (quoting Barker, 407 U.S. at 537 (White, J., concurring))).

22
United States v. Battisgreen
ca3 · 2009 · cited in 2 Idaho opinions naming this issue, 2024–2024
2 sentences

2024United States v. Battis, 589 F.3d 673, 681 (3d Cir. 2009).

2024United States v. Battis, 589 F.3d 673, 681 (3d Cir. 2009).

22
State v. Crockettgreen
idahoctapp · 2011 · cited in 2 Idaho opinions naming this issue, 2012–2023
2 sentences

2023Young, 136 Idaho at 118 , 29 P.3d at 954 ; see also 13 State v. Risdon, 154 Idaho 244, 252 , 296 P.3d 1091, 1099 (Ct. App. 2012); State v. Crockett, 151 Idaho 674, 678 , 263 P.3d 139, 143 (Ct. App. 2011).

2023Young, 136 Idaho at 118 , 29 P.3d at 954 ; see also 13 State v. Risdon, 154 Idaho 244, 252 , 296 P.3d 1091, 1099 (Ct. App. 2012); State v. Crockett, 151 Idaho 674, 678 , 263 P.3d 139, 143 (Ct. App. 2011).

22
State v. Lindsaygreen
idaho · 1975 · cited in 2 Idaho opinions naming this issue, 2000–2023
2 sentences

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

22
State v. Campbellgreen
idahoctapp · 1983 · cited in 2 Idaho opinions naming this issue, 2016–2016
2 sentences

2016State v. Campbell, 104 Idaho 705, 708 , 662 P.2d 1149, 1152 (Ct. App. 1983).

2016State v. Campbell, 104 Idaho 705, 708 , 662 P.2d 1149, 1152 (Ct. App. 1983).

22
United States v. Loud Hawkgreen
scotus · 1986 · cited in 2 Idaho opinions naming this issue, 2011–2012
2 sentences

2012See Loud Hawk, 474 U.S. at 315 , 106 S.Ct. at 656 , 88 L.Ed.2d at 654 (alleging only a “possibility of prejudice is not sufficient to support” a claim of a speedy trial violation).

2012See Loud Hawk, 474 U.S. at 315 , 106 S.Ct. at 656 , 88 L.Ed.2d at 654 (alleging only a “possibility of prejudice is not sufficient to support” a claim of a speedy trial violation).

12
State v. Cotantgreen
idaho · 1993 · cited in 2 Idaho opinions naming this issue, 2001–2011
2 sentences

2011Young, 136 Idaho at 118 , 29 P.3d at 954 ; State v. Cotant, 123 Idaho 787, 790 , 852 P.2d 1384, 1387 (1993), overruled on other grounds by State v. Clark, 135 Idaho 255, 258-60 , 16 P.3d 931, 934-36 (2000).

2011Young, 136 Idaho at 118 , 29 P.3d at 954 ; State v. Cotant, 123 Idaho 787, 790 , 852 P.2d 1384, 1387 (1993), overruled on other grounds by State v. Clark, 135 Idaho 255, 258-60 , 16 P.3d 931, 934-36 (2000).

12
State v. Mansfieldgreen
idaho · 2024 · cited in 1 Idaho opinions naming this issue, 2025–2025
1 sentence

2025See State v. Mansfield, 174 Idaho 690 , 711, 559 P.3d 1177, 1198 (2024); State v. Young, 136 Idaho 113, 118 , 29 P.3d 949, 954 (2001). 6

11
United States v. Jeffrey Olsengreen
ca9 · 2022 · cited in 1 Idaho opinions naming this issue, 2024–2024
1 sentence

2024See, e.g., United States v. Jones, ___ F.3d ___, ____ (6th Cir. Feb. 9, 2023) (finding COVID-19 “orders were temporary and reasonably calculated to abate the spread of a global pandemic and, in turn, save lives,” and were therefore “rightly excluded” from the defendant’s statutory “speedy trial clock”); United States v. Olsen, 21 F.4th 1036, 1047 (9th Cir. 2022) (observing that “surely a global pandemic that has claimed more than half a million lives in this country, and nearly 60,000 in California alone, falls within such unique circumstances to permit a court to temporarily suspend jury tria

11
State v. Mark Lankfordgreen
idaho · 2017 · cited in 1 Idaho opinions naming this issue, 2023–2023
2 sentences

2023On appeal, Lankford argues: (1) that the district court abused its discretion when it allowed the State to question Lankford’s brother about statements Lankford made on a late- disclosed prison phone recording; (2) that the evidence is insufficient to support his conviction when the law of the case doctrine is applied to his case; and (3) that the district court erred in 2 In its briefing, the State denominates State v. Lankford, 162 Idaho 477, 484 , 399 P.3d 804, 811 (2017), as “Lankford III.” However, given the numerous appeals of both Mark and Bryan Lankford, “Mark Lankford III” is used to

2023On appeal, Lankford argues: (1) that the district court abused its discretion when it allowed the State to question Lankford’s brother about statements Lankford made on a late- disclosed prison phone recording; (2) that the evidence is insufficient to support his conviction when the law of the case doctrine is applied to his case; and (3) that the district court erred in 2 In its briefing, the State denominates State v. Lankford, 162 Idaho 477, 484 , 399 P.3d 804, 811 (2017), as “Lankford III.” However, given the numerous appeals of both Mark and Bryan Lankford, “Mark Lankford III” is used to

11
State v. Clarkgreen
idaho · 2000 · cited in 1 Idaho opinions naming this issue, 2011–2011
2 sentences

2011Young, 136 Idaho at 118 , 29 P.3d at 954 ; State v. Cotant, 123 Idaho 787, 790 , 852 P.2d 1384, 1387 (1993), overruled on other grounds by State v. Clark, 135 Idaho 255, 258-60 , 16 P.3d 931, 934-36 (2000).

2011Young, 136 Idaho at 118 , 29 P.3d at 954 ; State v. Cotant, 123 Idaho 787, 790 , 852 P.2d 1384, 1387 (1993), overruled on other grounds by State v. Clark, 135 Idaho 255, 258-60 , 16 P.3d 931, 934-36 (2000).

11
State v. Garciagreen
idahoctapp · 1995 · cited in 1 Idaho opinions naming this issue, 2008–2008
2 sentences

2008In State v. Garcia, 126 Idaho 836 , 892 P.2d 903 (Ct.App.1995), this Court addressed the importance of having an adverse ruling to review in the context of an allegation of a speedy trial violation: We note also that an alleged violation of speedy trial rights is particularly inappropriate for consideration for the first time on appeal because the appellate record, where no speedy trial challenge was raised below, is seldom adequate to permit resolution of the claim.

2008In State v. Garcia, 126 Idaho 836 , 892 P.2d 903 (Ct.App.1995), this Court addressed the importance of having an adverse ruling to review in the context of an allegation of a speedy trial violation: We note also that an alleged violation of speedy trial rights is particularly inappropriate for consideration for the first time on appeal because the appellate record, where no speedy trial challenge was raised below, is seldom adequate to permit resolution of the claim.

11
State v. Fifegreen
mont · 1981 · cited in 1 Idaho opinions naming this issue, 1988–1988
1 sentence

1988See, e.g., State v. Fife, 632 P.2d 712 (Mont.1981).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Hadlock v. State green
idaho · 1970
2 sentences

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

12023–2023
Ellenwood v. Cramer green
idaho · 1954
2 sentences

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

2023From there, both state and federal constitutional claims turn to the balancing test under Barker. 14 “[T]he ‘balancing test’ laid down in Barker v. Wingo, 407 U.S. 514 , 92 S.Ct. 2182 , 33 L.Ed.2d 101 (1972), is consistent with decisions of this Court stating that whether one has been deprived of his right to a speedy trial must be decided by reference to considerations in addition to the mere passage of time.” State v. Lindsay, 96 Idaho 474, 475 , 531 P.2d 236, 237 (1975) (citing Hadlock v. State, 93 Idaho 915 , 478 P.2d 295 (1973) and Ellenwood v. Cramer, 75 Idaho 338 , 272 P.2d 702 (1954))

12023–2023
New York v. Hill green
scotus · 2000
1 sentence

2019Rejecting this claim, the district court relied on New York v. Hill, 528 U.S. 110 (2000), to rule: “Scheduling is not a fundamental right.

12019–2019
State v. Lopez green
idahoctapp · 2007
1 sentence

2010Here, the late assertion of the right weighs significantly against Lopez in balancing the speedy trial factors. *903 Id. at 353, 160 P.3d at 1288 .

12010–2010
United States v. MacDonald green
scotus · 1982
1 sentence

2005Id.

12005–2005
State v. Sindak green
idaho · 1989
2 sentences

1994He urges this Court, therefore, to reverse our Supreme Court’s holding in State v. Sindak, 116 Idaho 185 , 774 P.2d 895 (1989), cert. denied, sub nom., Sindak v. Idaho, 493 U.S. 1076 , 110 S.Ct. 1125 , 107 L.Ed.2d 1032 (1990), which is the controlling law on the issue of speedy trial rights under I.C. § 19-3501.

1994He urges this Court, therefore, to reverse our Supreme Court’s holding in State v. Sindak, 116 Idaho 185 , 774 P.2d 895 (1989), cert. denied, sub nom., Sindak v. Idaho, 493 U.S. 1076 , 110 S.Ct. 1125 , 107 L.Ed.2d 1032 (1990), which is the controlling law on the issue of speedy trial rights under I.C. § 19-3501.

11994–1994
Bausch & Lomb Inc. v. Hewlett-Packard Co. green
scotus · 1990
1 sentence

1994He urges this Court, therefore, to reverse our Supreme Court’s holding in State v. Sindak, 116 Idaho 185 , 774 P.2d 895 (1989), cert. denied, sub nom., Sindak v. Idaho, 493 U.S. 1076 , 110 S.Ct. 1125 , 107 L.Ed.2d 1032 (1990), which is the controlling law on the issue of speedy trial rights under I.C. § 19-3501.

11994–1994
Standard Oil Co. of California v. City of Long Beach green
scotus · 1990
1 sentence

1994He urges this Court, therefore, to reverse our Supreme Court’s holding in State v. Sindak, 116 Idaho 185 , 774 P.2d 895 (1989), cert. denied, sub nom., Sindak v. Idaho, 493 U.S. 1076 , 110 S.Ct. 1125 , 107 L.Ed.2d 1032 (1990), which is the controlling law on the issue of speedy trial rights under I.C. § 19-3501.

11994–1994
Adair v. Clay green
scotus · 1990
1 sentence

1994He urges this Court, therefore, to reverse our Supreme Court’s holding in State v. Sindak, 116 Idaho 185 , 774 P.2d 895 (1989), cert. denied, sub nom., Sindak v. Idaho, 493 U.S. 1076 , 110 S.Ct. 1125 , 107 L.Ed.2d 1032 (1990), which is the controlling law on the issue of speedy trial rights under I.C. § 19-3501.

11994–1994
State v. Talmage green
idaho · 1983
2 sentences

1986State v. Talmage, 104 Idaho 249 , 658 P.2d 920 (1983).

1986State v. Talmage, 104 Idaho 249 , 658 P.2d 920 (1983).

11986–1986
State v. Holtslander green
idaho · 1981
2 sentences

1986State v. Holtslander, 102 Idaho 306 , 629 P.2d 702 (1981); State v. Russell, supra. Here the aggregate length of time elapsing between Mason’s summons to appear on the refiled assault charge and the date his trial began was approximately seven and one-half months.

1986State v. Holtslander, 102 Idaho 306 , 629 P.2d 702 (1981); State v. Russell, supra. Here the aggregate length of time elapsing between Mason’s summons to appear on the refiled assault charge and the date his trial began was approximately seven and one-half months.

11986–1986
United States v. Marion green
scotus · 1971
11978–1978
Schrom v. Cramer green
idaho · 1954
11963–1963

Statutes the citing opinions construe

ID § Idaho Code § 19-3501 (21) ID § Idaho Code § 18-8004 (4) ID § Idaho Code § 18-1508A (3) ID § Idaho Code § 18-905 (3) ID § Idaho Code § 19-2514 (3)

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.

Where else courts name it

TX 640 (1973–2026) OH 496 (1978–2026) FL 395 (1969–2026) NM 272 (1978–2026) IL 210 (1971–2026) WA 190 (1976–2026) GA 155 (1969–2026) MS 148 (1988–2026) PA 137 (1970–2026) NY 133 (1972–2026) MI 118 (1975–2026) MT 116 (1978–2026) AR 115 (1979–2026) CA 114 (1962–2026) TN 103 (1969–2026) AL 64 (1972–2026) WY 62 (1979–2023) DC 62 (1965–2014) IA 59 (1971–2026) NJ 56 (1974–2025) IN 55 (1982–2024) MD 53 (1968–2025) OR 49 (1970–2026) MO 48 (1972–2025) LA 44 (1979–2025) AZ 44 (1976–2026) CO 40 (1975–2026) KS 38 (1978–2026) VA 36 (1987–2025) MN 35 (1978–2025) NC 35 (1981–2026) MA 33 (1973–2025) ID 29 (1963–2025) CT 28 (1981–2023) WI 26 (1990–2026) VT 26 (1984–2024) AK 25 (1971–2025) DE 24 (1979–2026) ND 23 (1993–2025) NH 23 (1981–2022) RI 20 (1979–2015) KY 18 (1995–2026) NV 18 (1967–2026) ME 17 (1972–2026) UT 17 (1968–2026) NE 17 (1989–2025) SC 16 (1986–2026) HI 11 (1980–2025) OK 10 (1970–2023) WV 9 (1979–2010) VI 7 (1990–2026) SD 6 (1988–2026)

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.

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