statutory speedy trial analysis (Kansas) · Go Syfert
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statutory speedy trial analysis in Kansas

14 Kansas opinions name it 2 courts 1997–2024 5 in the last five years

The cases below were cited by Kansas 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 (8)

CaseFollowedCited
State v. Brownleegreen
kan · 2015 · cited in 4 Kansas opinions naming this issue, 2016–2021
2 sentences

2020Dupree, 304 Kan. at 49-50 ("[W]e recently confirmed a defendant must have an opportunity to be present to express disagreement with a continuance because a defendant's disagreement matters in the statutory speedy trial analysis."); Brownlee, 302 Kan. at 508 .

2020Moreover, our Supreme Court has found that a district court commits a statutory speedy trial error when the defendant is not present at a hearing on a motion to continue trial in order to voice an objection. 302 Kan. at 508 .

24
State v. Dupreegreen
kan · 2016 · cited in 5 Kansas opinions naming this issue, 2017–2020
2 sentences

2020Our Supreme Court held: "'Because a defendant's disagreement matters in a statutory speedy trial analysis, a defendant must have an opportunity to be present to express that disagreement.' State v. Dupree, 304 Kan. 43 , Syl. ¶ 2, 371 P.3d 862 (2016)." 305 Kan. at 1178.

2020Dupree, 304 Kan. at 49-50 ("[W]e recently confirmed a defendant must have an opportunity to be present to express disagreement with a continuance because a defendant's disagreement matters in the statutory speedy trial analysis."); Brownlee, 302 Kan. at 508 .

15
State v. Gillgreen
kanctapp · 2012 · cited in 1 Kansas opinions naming this issue, 2024–2024
1 sentence

2024See Gill, 48 Kan.

11
State v. Arnettgreen
kan · 2018 · cited in 1 Kansas opinions naming this issue, 2022–2022
1 sentence

2022See Arnett, 307 Kan. at 650 (issue not briefed deemed waived or abandoned).

11
State v. McDanielsgreen
kan · 1985 · cited in 1 Kansas opinions naming this issue, 2016–2016
1 sentence

2016First, K.S.A. 2014 Supp. 22-3402(g) only removes the remedy for a statutory speedy trial violation and does so in only some circumstances, stating: “If a delay is initially attributed to the defendant, but is subsequently charged to the state for any reason, such delay . . . shall not be used as a ground for dismissing a case or for reversing a conviction.” Granted, removal of the remedy in those limited circumstances undercuts the statutory right, but “the general rule is that there are no vested rights in a particular remedy or method of procedure.” Owen Lumber, 276 Kan. at 222 ; see also Mc

11
State v. Smallwoodgreen
kan · 1998 · cited in 1 Kansas opinions naming this issue, 2016–2016
2 sentences

2016See, e.g., State v. Smallwood, 264 Kan. 69, 74-76 , 955 P.2d 1209 (1998) (analyzing a statutory speedy trial challenge differently than a constitutional challenge).

2016See, e.g., State v. Smallwood, 264 Kan. 69, 74-76 , 955 P.2d 1209 (1998) (analyzing a statutory speedy trial challenge differently than a constitutional challenge).

11
State v. Taylorgreen
kanctapp · 2011 · cited in 1 Kansas opinions naming this issue, 2016–2016
1 sentence

2016See State v. Brownlee, 302 Kan. 491, 508 , 354 P.3d 525 (2015) (agreeing that a defendant should be present at a hearing on a defense motion to continue); see also K.S.A. 2014 Supp. 22-3208(7) (stating defendants right to be present at a motion hearing); State v. Taylor, No. 104,455, 2011 WL 3795481, at *4 (Kan.

11
State v. Gossgreen
kan · 1989 · cited in 1 Kansas opinions naming this issue, 1997–1997
2 sentences

1997Green , in which a statutory speedy trial violation was asserted and *898 denied, controls here. 260 Kan. at 473; see State v. Gross, 245 Kan. 189, 191 , 777 P.2d 781 (1989).

1997Green , in which a statutory speedy trial violation was asserted and *898 denied, controls here. 260 Kan. at 473; see State v. Gross, 245 Kan. 189, 191 , 777 P.2d 781 (1989).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Brownleegreen
kan · 2015 · cited in 4 Kansas opinions naming this issue, 2016–2021
2 sentences

2020Dupree, 304 Kan. at 49-50 ("[W]e recently confirmed a defendant must have an opportunity to be present to express disagreement with a continuance because a defendant's disagreement matters in the statutory speedy trial analysis."); Brownlee, 302 Kan. at 508 .

2020Moreover, our Supreme Court has found that a district court commits a statutory speedy trial error when the defendant is not present at a hearing on a motion to continue trial in order to voice an objection. 302 Kan. at 508 .

14

Also cited on this issue (10)

CaseCitedYears
State v. Betts green
kan · 2022
1 sentence

2024State v. Betts, 316 Kan. 191 , 197, 514 P.3d 341 (2022).

12024–2024
State v. Jakeway green
kan · 1976
1 sentence

2021Instead, Jakeway involved a defendant challenging his conviction after a jury trial because he was not formally arraigned. 221 Kan. at 143-44 .

12021–2021
State v. White green
kan · 2003
2 sentences

2020State v. White, 275 Kan. 580, 598 , 67 P.3d 138 (2003).

2020State v. White, 275 Kan. 580, 598 , 67 P.3d 138 (2003).

12020–2020
State v. King green
kan · 2013
2 sentences

2020Additionally, the Sixth Amendment guarantees that "a criminal defendant may be present at every critical stage of his or her trial." State v. King, 297 Kan. 955, 968 , 305 P.3d 641 (2013).

2020Additionally, the Sixth Amendment guarantees that "a criminal defendant may be present at every critical stage of his or her trial." State v. King, 297 Kan. 955, 968 , 305 P.3d 641 (2013).

12020–2020
State v. Adams green
kan · 2007
2 sentences

2020State v. Adams, 283 Kan. 365, 368 , 153 P.3d 512 (2007).

2020State v. Adams, 283 Kan. 365, 368 , 153 P.3d 512 (2007).

12020–2020
Owen Lumber Co. v. Chartrand green
kan · 2003
1 sentence

2016First, K.S.A. 2014 Supp. 22-3402(g) only removes the remedy for a statutory speedy trial violation and does so in only some circumstances, stating: “If a delay is initially attributed to the defendant, but is subsequently charged to the state for any reason, such delay . . . shall not be used as a ground for dismissing a case or for reversing a conviction.” Granted, removal of the remedy in those limited circumstances undercuts the statutory right, but “the general rule is that there are no vested rights in a particular remedy or method of procedure.” Owen Lumber, 276 Kan. at 222 ; see also Mc

12016–2016
State v. Sherman green
kan · 1974
1 sentence

2007Sherman involved a delay resulting from the defendant’s requests for continuances and failure to appear. 217 Kan. at 329 .

12007–2007
State v. Fitch green
kan · 1991
1 sentence

2007Fitch involved a constitutional speedy trial analysis rather than a statutory speedy trial analysis. 249 Kan. at 563 .

12007–2007
State v. Abel green
kan · 1997
1 sentence

1997However, during oral argument, Mathenia’s counsel advanced a statutory speedy trial claim relying on Abel, 261 Kan. 331 , and Noriega, 261 Kan. 440 .

11997–1997
State v. Noriega green
kan · 1997
1 sentence

1997However, during oral argument, Mathenia’s counsel advanced a statutory speedy trial claim relying on Abel, 261 Kan. 331 , and Noriega, 261 Kan. 440 .

11997–1997

Statutes the citing opinions construe

KS § K.S.A. § 22-3402 (13) KS § K.S.A. § 22-3601 (4) KS § K.S.A. § 22-3208 (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

NY 49 (1983–2026) VA 32 (1997–2026) IL 30 (1994–2026) OH 25 (1995–2026) CA 15 (1997–2025) KS 14 (1997–2024) OR 13 (2002–2021) MS 8 (1998–2022) LA 8 (1994–2019) NV 4 (2019–2021) CO 4 (2014–2025) MD 3 (1988–2004) ID 3 (2009–2025) MT 3 (2016–2024) NM 3 (1989–1995) NE 2 (2021–2021) WI 2 (2004–2023) GA 2 (2020–2023) MO 2 (2019–2019)

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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