statutory speedy trial claim (Oregon) · Go Syfert
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statutory speedy trial claim in Oregon

13 Oregon opinions name it 2 courts 2002–2021 1 in the last five years

The cases below were cited by Oregon 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 (6)

CaseFollowedCited
State v. Johnsongreen
or · 2007 · cited in 2 Oregon opinions naming this issue, 2009–2020
2 sentences

2020See State v. Rohlfing, 155 Or App 127, 129 , 963 P2d 87 (1998) (reviewing for errors of law a statutory speedy-trial challenge under former ORS 135.747 (1997)); Johnson, 342 Or at 608 (reviewing for errors of law under a constitutional speedy-trial challenge).

2020See Johnson, 342 Or at 606 (explaining that “[w]e do so because a defendant who pre- vails on a constitutional speedy trial claim is entitled to dis- missal with prejudice,” whereas a defendant who prevails on a statutory speedy trial claim “is entitled only to dismissal without prejudice”).7 We address defendant’s state constitutional claim first.

12
State v. Dixongreen
orctapp · 2008 · cited in 1 Oregon opinions naming this issue, 2021–2021
2 sentences

2021See State v. Dixon, 224 Or App 66, 73, 75 , 197 P3d 1106 (2008), rev den, 346 Or 10 (2009) (concluding that, for pur- poses of a statutory speedy trial claim, a six-month period “arose out of routine delays,” including “one month from indictment to arraignment, a one-month delay to appoint substitute counsel, and a four-month delay from the first court appearance to the first scheduled trial date”).

2021See State v. Dixon, 224 Or App 66, 73, 75 , 197 P3d 1106 (2008), rev den, 346 Or 10 (2009) (concluding that, for pur- poses of a statutory speedy trial claim, a six-month period “arose out of routine delays,” including “one month from indictment to arraignment, a one-month delay to appoint substitute counsel, and a four-month delay from the first court appearance to the first scheduled trial date”).

11
State v. Gonzales-Sanchezgreen
orctapp · 2012 · cited in 1 Oregon opinions naming this issue, 2021–2021
2 sentences

2021See State v. Gonzales-Sanchez, 251 Or App 118, 124, 126 , 282 P3d 19 , rev den, 352 Or 666 (2012) (concluding that the state “made sufficient efforts” to serve the warrant for purposes of a statutory speedy trial claim where it did not have defendant’s out-of-state mailing address and it entered the warrant into two law enforcement databases); State v. Green, 140 Or App 308 , 315 n 9, 915 P2d 460 (1996) (noting that the “unreasonable delay test [for determining whether a prosecution was initiated within the statute of limitations under ORS 131.135] is the same as the speedy trial analysis unde

2021See State v. Gonzales-Sanchez, 251 Or App 118, 124, 126 , 282 P3d 19 , rev den, 352 Or 666 (2012) (concluding that the state “made sufficient efforts” to serve the warrant for purposes of a statutory speedy trial claim where it did not have defendant’s out-of-state mailing address and it entered the warrant into two law enforcement databases); State v. Green, 140 Or App 308 , 315 n 9, 915 P2d 460 (1996) (noting that the “unreasonable delay test [for determining whether a prosecution was initiated within the statute of limitations under ORS 131.135] is the same as the speedy trial analysis unde

11
State v. Groszgreen
or · 2009 · cited in 1 Oregon opinions naming this issue, 2021–2021
1 sentence

2021See State v. Dixon, 224 Or App 66, 73, 75 , 197 P3d 1106 (2008), rev den, 346 Or 10 (2009) (concluding that, for pur- poses of a statutory speedy trial claim, a six-month period “arose out of routine delays,” including “one month from indictment to arraignment, a one-month delay to appoint substitute counsel, and a four-month delay from the first court appearance to the first scheduled trial date”).

11
State v. Rohlfinggreen
orctapp · 1998 · cited in 1 Oregon opinions naming this issue, 2020–2020
2 sentences

2020See State v. Rohlfing, 155 Or App 127, 129 , 963 P2d 87 (1998) (reviewing for errors of law a statutory speedy-trial challenge under former ORS 135.747 (1997)); Johnson, 342 Or at 608 (reviewing for errors of law under a constitutional speedy-trial challenge).

2020See State v. Rohlfing, 155 Or App 127, 129 , 963 P2d 87 (1998) (reviewing for errors of law a statutory speedy-trial challenge under former ORS 135.747 (1997)); Johnson, 342 Or at 608 (reviewing for errors of law under a constitutional speedy-trial challenge).

11
State v. Velykoretskykhgreen
orctapp · 2015 · cited in 1 Oregon opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., State v. Velykoretskykh, 268 Or App 706 , 707 n 2, 343 P3d 272 (2015) (“Under Oregon court’s ‘first things first’ doctrine, we have an obligation to address state consti- tutional law claims before federal ones.”).

2020See, e.g., State v. Velykoretskykh, 268 Or App 706 , 707 n 2, 343 P3d 272 (2015) (“Under Oregon court’s ‘first things first’ doctrine, we have an obligation to address state consti- tutional law claims before federal ones.”).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Emerygreen
or · 1994 · cited in 1 Oregon opinions naming this issue, 2004–2004
1 sentence

2004But see Emery, 318 Or at 470 (prejudice inquiry is irrelevant to a statutory speedy trial claim).

11

Also cited on this issue (13)

CaseCitedYears
State v. GLUSHKO green
or · 2011
2 sentences

2014On appeal, both parties acknowledge that the trial court did not apply the correct statutory speedy-trial analysis as the Supreme Court explained it in State v. Glushko/Little, 351 Or 297 , 266 P3d 50 (2011), which was decided eight days before the trial court’s ruling.

2014On appeal, both parties acknowledge that the trial court did not apply the correct statutory speedy-trial analysis as the Supreme Court explained it in State v. Glushko/Little, 351 Or 297 , 266 P3d 50 (2011), which was decided eight days before the trial court’s ruling.

22014–2014
State v. Davids green
or · 2005
2 sentences

2012State v. Adams, 339 Or 104 , 116 P3d 898 (2005); State v. Davids, 339 Or 96 , 116 P3d 894 (2005); State v. Johnson, 339 Or 69 , 116 P3d 879 (2005).

2012State v. Adams, 339 Or 104 , 116 P3d 898 (2005); State v. Davids, 339 Or 96 , 116 P3d 894 (2005); State v. Johnson, 339 Or 69 , 116 P3d 879 (2005).

22010–2012
State v. Adams green
or · 2005
2 sentences

2012State v. Adams, 339 Or 104 , 116 P3d 898 (2005); State v. Davids, 339 Or 96 , 116 P3d 894 (2005); State v. Johnson, 339 Or 69 , 116 P3d 879 (2005).

2012State v. Adams, 339 Or 104 , 116 P3d 898 (2005); State v. Davids, 339 Or 96 , 116 P3d 894 (2005); State v. Johnson, 339 Or 69 , 116 P3d 879 (2005).

22010–2012
State v. Johnson green
or · 2005
2 sentences

2012State v. Adams, 339 Or 104 , 116 P3d 898 (2005); State v. Davids, 339 Or 96 , 116 P3d 894 (2005); State v. Johnson, 339 Or 69 , 116 P3d 879 (2005).

2012State v. Adams, 339 Or 104 , 116 P3d 898 (2005); State v. Davids, 339 Or 96 , 116 P3d 894 (2005); State v. Johnson, 339 Or 69 , 116 P3d 879 (2005).

22010–2012
State v. Pirouzkar green
orctapp · 1989
2 sentences

2021See State v. Gonzales-Sanchez, 251 Or App 118, 124, 126 , 282 P3d 19 , rev den, 352 Or 666 (2012) (concluding that the state “made sufficient efforts” to serve the warrant for purposes of a statutory speedy trial claim where it did not have defendant’s out-of-state mailing address and it entered the warrant into two law enforcement databases); State v. Green, 140 Or App 308 , 315 n 9, 915 P2d 460 (1996) (noting that the “unreasonable delay test [for determining whether a prosecution was initiated within the statute of limitations under ORS 131.135] is the same as the speedy trial analysis unde

2021See State v. Gonzales-Sanchez, 251 Or App 118, 124, 126 , 282 P3d 19 , rev den, 352 Or 666 (2012) (concluding that the state “made sufficient efforts” to serve the warrant for purposes of a statutory speedy trial claim where it did not have defendant’s out-of-state mailing address and it entered the warrant into two law enforcement databases); State v. Green, 140 Or App 308 , 315 n 9, 915 P2d 460 (1996) (noting that the “unreasonable delay test [for determining whether a prosecution was initiated within the statute of limitations under ORS 131.135] is the same as the speedy trial analysis unde

12021–2021
State v. Green green
orctapp · 1996
2 sentences

2021See State v. Gonzales-Sanchez, 251 Or App 118, 124, 126 , 282 P3d 19 , rev den, 352 Or 666 (2012) (concluding that the state “made sufficient efforts” to serve the warrant for purposes of a statutory speedy trial claim where it did not have defendant’s out-of-state mailing address and it entered the warrant into two law enforcement databases); State v. Green, 140 Or App 308 , 315 n 9, 915 P2d 460 (1996) (noting that the “unreasonable delay test [for determining whether a prosecution was initiated within the statute of limitations under ORS 131.135] is the same as the speedy trial analysis unde

2021See State v. Gonzales-Sanchez, 251 Or App 118, 124, 126 , 282 P3d 19 , rev den, 352 Or 666 (2012) (concluding that the state “made sufficient efforts” to serve the warrant for purposes of a statutory speedy trial claim where it did not have defendant’s out-of-state mailing address and it entered the warrant into two law enforcement databases); State v. Green, 140 Or App 308 , 315 n 9, 915 P2d 460 (1996) (noting that the “unreasonable delay test [for determining whether a prosecution was initiated within the statute of limitations under ORS 131.135] is the same as the speedy trial analysis unde

12021–2021
State v. Ellis neutral
orctapp · 2014
2 sentences

2016In response, defendant relies on Ellis, 263 Or App at 252 , which states that, “[t]he total period of delay begins when a defendant is charged and ends on the last date set for trial.” We agree with defendant that the correct calculation in a statutory speedy trial analysis for the total period of delay begins “when a defendant is charged” and ends “on the last day set for trial.” Id.

2016In response, defendant relies on Ellis, 263 Or App at 252 , which states that, “[t]he total period of delay begins when a defendant is charged and ends on the last date set for trial.” We agree with defendant that the correct calculation in a statutory speedy trial analysis for the total period of delay begins “when a defendant is charged” and ends “on the last day set for trial.” Id.

12016–2016
State v. Coulson green
orctapp · 2011
2 sentences

2014Defendant argued that, under State v. Coulson, 243 Or App 257 , 258 P3d 1253 (2011), “there is no per se rule that a Failure to Appear equals consent”; under the circumstances, he argued, his conversation with the clerk effectively negated the notice of his obligation to appear.

2014Defendant argued that, under State v. Coulson, 243 Or App 257 , 258 P3d 1253 (2011), “there is no per se rule that a Failure to Appear equals consent”; under the circumstances, he argued, his conversation with the clerk effectively negated the notice of his obligation to appear.

12014–2014
State v. LINH THAT CAM TON green
orctapp · 2010
2 sentences

2012As we explained in State v. Ton, 237 Or App 447, 450 , 241 P3d 309 (2010), we follow an established methodology in evaluating a statutory speedy trial claim: “The Oregon Supreme Court decided a trilogy of cases in 2005 that, when read together, set out a three-step process for determining whether the state has violated the statutory speedy trial requirement of ORS 135.747.

2012As we explained in State v. Ton, 237 Or App 447, 450 , 241 P3d 309 (2010), we follow an established methodology in evaluating a statutory speedy trial claim: “The Oregon Supreme Court decided a trilogy of cases in 2005 that, when read together, set out a three-step process for determining whether the state has violated the statutory speedy trial requirement of ORS 135.747.

12012–2012
State v. Harberts green
or · 2000
1 sentence

2007Id.

12007–2007
State v. Harman green
orctapp · 2002
1 sentence

2006However, we have previously found the state to have violated the statutory speedy trial requirement where a defendant consented to or occasioned a majority of pretrial delay, Harman, 179 Or App at 622-23 , and we see no need here to establish a rule that when a defendant has consented *758 to or occasioned a majority of the period of delay to trial, he must be deemed to have consented to all of it.

12006–2006
State v. Jackson green
or · 1961
2 sentences

2005State v. Jackson, 228 Or 371, 377-78 , 365 P2d 294 (1961).

2005State v. Jackson, 228 Or 371, 377-78 , 365 P2d 294 (1961).

12005–2005
State v. McQueen green
orctapp · 1998
2 sentences

2002In State v. McQueen, 153 Or App 277, 281 , 956 P2d 1046 , rev den 327 Or 554 (1998), we considered that same categorical exclusion argument and concluded that a defendant whose trial was postponed upon his application or consent could nevertheless maintain a statutory speedy trial claim to the extent that his claim is based on delay beyond that to which he consented.

2002In State v. McQueen, 153 Or App 277, 281 , 956 P2d 1046 , rev den 327 Or 554 (1998), we considered that same categorical exclusion argument and concluded that a defendant whose trial was postponed upon his application or consent could nevertheless maintain a statutory speedy trial claim to the extent that his claim is based on delay beyond that to which he consented.

12002–2002

Statutes the citing opinions construe

OR § Or. Rev. Stat. § 135.750 (5) OR § Or. Rev. Stat. § 813.010 (5) OR § Or. Rev. Stat. § 131.125 (3) OR § Or. Rev. Stat. § 131.135 (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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