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

11 Hawaii opinions name it 2 courts 1980–2025 2 in the last five years

The cases below were cited by Hawaii 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 (11)

CaseFollowedCited
State v. Ferrarogreen
hawapp · 1990 · cited in 2 Hawaii opinions naming this issue, 1994–2005
2 sentences

2005This court found in State v. Ferraro, 8 Haw.App. 284 , 800 P.2d 623 (1990), that “[prejudice in a speedy trial claim is evaluated in the light of the interests protected by the right.

2005This court found in State v. Ferraro, 8 Haw.App. 284 , 800 P.2d 623 (1990), that “[prejudice in a speedy trial claim is evaluated in the light of the interests protected by the right.

12
State v. Whitegreen
haw · 1999 · cited in 1 Hawaii opinions naming this issue, 2025–2025
2 sentences

2025See id. at 203 , 990 P.2d at 101 (holding that eleven-month delay warranted inquiry into the other Barker factors).

2025See id. at 203 , 990 P.2d at 101 (holding that eleven-month delay warranted inquiry into the other Barker factors).

11
State v. Visintin.green
haw · 2018 · cited in 1 Hawaii opinions naming this issue, 2020–2020
1 sentence

2020While 8 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER there are no other "findings" in the record that touch upon the Barker factors, and no written findings entered, it appears that Preston's trial was conducted over a period of nearly six months, on seven trial days, in roughly one to two hour segments.4 In State v. Visintin, 143 Hawai#i 143, 157-58, 426 P.3d 367, 381-82 (2018), the supreme court held that this court erred in considering the defendant's speedy trial claim on the merits because the trial court in that case had not considered the Barker factors and had not

11
United States v. Ernesto Godoy, Fermin Enrique Bergouignangreen
ca11 · 1987 · cited in 1 Hawaii opinions naming this issue, 2017–2017
1 sentence

2017See United States v. Godoy, 821 F.2d 1498, 1506 (11th Cir. 1987) (stating that the defendants failed to show “any unique circumstances” that weigh on the impact of reprosecution on the administration of the speedy trial rule and on the administration of justice).

11
Llewyn J. Cowart v. Edward Hargett, Superintendent, Mississippi State Penitentiarygreen
ca5 · 1994 · cited in 1 Hawaii opinions naming this issue, 1995–1995
1 sentence

1995Rather, the defendants moved only to have the charges dismissed, and “an assertion that charges be dismissed for a speedy trial violation is not a protected value under Barker.” Cowart v. Hargett, 16 F.3d 642, 647 (5th Cir.1994), cert. denied, — U.S. -, 115 S.Ct. 227 , 130 L.Ed.2d 153 (1994) (citing Hill v. Wainwright, 617 F.2d 375, 379 (5th Cir.1980)).

11
Paul Clifford Hill v. Louie L. Wainwright, Etc.green
ca5 · 1980 · cited in 1 Hawaii opinions naming this issue, 1995–1995
1 sentence

1995Rather, the defendants moved only to have the charges dismissed, and “an assertion that charges be dismissed for a speedy trial violation is not a protected value under Barker.” Cowart v. Hargett, 16 F.3d 642, 647 (5th Cir.1994), cert. denied, — U.S. -, 115 S.Ct. 227 , 130 L.Ed.2d 153 (1994) (citing Hill v. Wainwright, 617 F.2d 375, 379 (5th Cir.1980)).

11
Reed v. United Statesgreen
dc · 1978 · cited in 1 Hawaii opinions naming this issue, 1994–1994
1 sentence

1994State v. Ferraro, 8 Haw.App. 284, 300 , 800 P.2d 623, 632 (1990) (“ ‘[A] mere assertion that one had been upset or concerned about a pending criminal prosecution is not sufficient’ to establish prejudicial anxiety.” (quoting Reed v. United States, 383 A.2d 316, 320 (D.C.), cert. denied, 439 U.S. 871 , 99 S.Ct. 203 , 58 L.Ed.2d 183 (1978))); see also United States v. Simmons, 536 F.2d 827, 831-32 (9th Cir.) (“Conclusory allegations of general anxiety and depression are present in almost every criminal prosecution.

11
United States v. James Henry Simmonsgreen
ca9 · 1976 · cited in 1 Hawaii opinions naming this issue, 1994–1994
1 sentence

1994State v. Ferraro, 8 Haw.App. 284, 300 , 800 P.2d 623, 632 (1990) (“ ‘[A] mere assertion that one had been upset or concerned about a pending criminal prosecution is not sufficient’ to establish prejudicial anxiety.” (quoting Reed v. United States, 383 A.2d 316, 320 (D.C.), cert. denied, 439 U.S. 871 , 99 S.Ct. 203 , 58 L.Ed.2d 183 (1978))); see also United States v. Simmons, 536 F.2d 827, 831-32 (9th Cir.) (“Conclusory allegations of general anxiety and depression are present in almost every criminal prosecution.

11
United States v. Phillip Kent Palmer, Joseph Philip Silverman, Ernest Smith, Freddie Daniel Milton, Edward Earl Dillingham and Wayne Franklin Deangreen
ca5 · 1976 · cited in 1 Hawaii opinions naming this issue, 1980–1980
1 sentence

1980United States v. Garza, 547 F.2d 1234, 1235 (5th Cir. 1977) (14 month delay between arrest and indictment); United States v. Edwards, 577 F.2d 883, 887-88 (5th Cir. 1978) (13 month delay between arrest and indictment); United States v. Palmer, 537 F.2d 1287, 1288 (5th Cir. 1976) (22 month delay between arrest and indictment).

11
United States v. Arnoldo Cantu Garzagreen
ca5 · 1977 · cited in 1 Hawaii opinions naming this issue, 1980–1980
1 sentence

1980United States v. Garza, 547 F.2d 1234, 1235 (5th Cir. 1977) (14 month delay between arrest and indictment); United States v. Edwards, 577 F.2d 883, 887-88 (5th Cir. 1978) (13 month delay between arrest and indictment); United States v. Palmer, 537 F.2d 1287, 1288 (5th Cir. 1976) (22 month delay between arrest and indictment).

11
United States v. Alvin Leon Edwardsgreen
ca5 · 1978 · cited in 1 Hawaii opinions naming this issue, 1980–1980
1 sentence

1980United States v. Garza, 547 F.2d 1234, 1235 (5th Cir. 1977) (14 month delay between arrest and indictment); United States v. Edwards, 577 F.2d 883, 887-88 (5th Cir. 1978) (13 month delay between arrest and indictment); United States v. Palmer, 537 F.2d 1287, 1288 (5th Cir. 1976) (22 month delay between arrest and indictment).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Hawaii v. Nihipali green
haw · 1981
2 sentences

1995But Appellant also asserts a violation of his constitutional right to a speedy trial and “[t]he only remedy for the violation of an accused’s right to a speedy trial is a dismissal with prejudice.” State v. Nihipali, 64 Haw. 65 , 67 n. 4, 637 P.2d 407 , 408 n. 4 (1981) (emphasis added).

1995But Appellant also asserts a violation of his constitutional right to a speedy trial and “[t]he only remedy for the violation of an accused’s right to a speedy trial is a dismissal with prejudice.” State v. Nihipali, 64 Haw. 65 , 67 n. 4, 637 P.2d 407 , 408 n. 4 (1981) (emphasis added).

21995–1995
Barker v. Wingo green
scotus · 1972
2 sentences

1994While we can safely assume that Wasson, like most criminal defendants, suffered some anxious moments awaiting his trial, see Barker, 407 U.S. at 533 , 92 S.Ct. at 2193 , nevertheless, for purposes of the speedy trial analysis, something more than a bare assertion of disquietude is generally required before this form of prejudice will weigh in favor of the accused.

1994While we can safely assume that Wasson, like most criminal defendants, suffered some anxious moments awaiting his trial, see Barker, 407 U.S. at 533 , 92 S.Ct. at 2193 , nevertheless, for purposes of the speedy trial analysis, something more than a bare assertion of disquietude is generally required before this form of prejudice will weigh in favor of the accused.

21990–1994
State v. Estencion green
haw · 1981
2 sentences

2024Although the Circuit Court's examination of this factor is minimal, based on the record before it, we cannot conclude that the Circuit Court abused its discretion in finding this factor weighed in favor of dismissal with prejudice. 4 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER The third Estencion factor requires consideration of the impact of reprosecution on the administration of the speedy trial rule and on the administration of justice. 63 Haw. at 269 , 625 P.2d at 1044 .

2024Although the Circuit Court's examination of this factor is minimal, based on the record before it, we cannot conclude that the Circuit Court abused its discretion in finding this factor weighed in favor of dismissal with prejudice. 4 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER The third Estencion factor requires consideration of the impact of reprosecution on the administration of the speedy trial rule and on the administration of justice. 63 Haw. at 269 , 625 P.2d at 1044 .

12024–2024
State v. Jackson green
haw · 1996
2 sentences

2014Finally, this court has examined the defendant’s sufficiency of the evidence claim prior to remand for a violation of the speedy trial rule under Hawai'i Rules of Penal Procedure (HRPP) Rule 48. 15 In State v. Jackson, 81 Hawai'i 39 , 912 P.2d 71 (1996), the court held that the trial court erred in denying the defendant’s HRPP Rule 48 motion to dismiss.

2014Finally, this court has examined the defendant’s sufficiency of the evidence claim prior to remand for a violation of the speedy trial rule under Hawai#i Rules of Penal Procedure (HRPP) Rule 48.15 In State v. Jackson, 81 Hawai#i 39, 912 P.2d 71 15 HRPP Rule 48(b)(1) (2000) generally provides that “the court shall, on motion of the defendant, dismiss the charge, with or without prejudice in its discretion, if trial is not commenced within 6 months” from the date of arrest if bail is set or from the filing of the charge, whichever (continued...) 39 *** FOR PUBLICATION IN WEST’S HAWAI#I REPORTS A

12014–2014
Naddi v. California green
scotus · 1994
1 sentence

1995Rather, the defendants moved only to have the charges dismissed, and “an assertion that charges be dismissed for a speedy trial violation is not a protected value under Barker.” Cowart v. Hargett, 16 F.3d 642, 647 (5th Cir.1994), cert. denied, — U.S. -, 115 S.Ct. 227 , 130 L.Ed.2d 153 (1994) (citing Hill v. Wainwright, 617 F.2d 375, 379 (5th Cir.1980)).

11995–1995
Card v. Denton green
scotus · 1978
1 sentence

1994State v. Ferraro, 8 Haw.App. 284, 300 , 800 P.2d 623, 632 (1990) (“ ‘[A] mere assertion that one had been upset or concerned about a pending criminal prosecution is not sufficient’ to establish prejudicial anxiety.” (quoting Reed v. United States, 383 A.2d 316, 320 (D.C.), cert. denied, 439 U.S. 871 , 99 S.Ct. 203 , 58 L.Ed.2d 183 (1978))); see also United States v. Simmons, 536 F.2d 827, 831-32 (9th Cir.) (“Conclusory allegations of general anxiety and depression are present in almost every criminal prosecution.

11994–1994
Bailey v. United States green
scotus · 1978
1 sentence

1994State v. Ferraro, 8 Haw.App. 284, 300 , 800 P.2d 623, 632 (1990) (“ ‘[A] mere assertion that one had been upset or concerned about a pending criminal prosecution is not sufficient’ to establish prejudicial anxiety.” (quoting Reed v. United States, 383 A.2d 316, 320 (D.C.), cert. denied, 439 U.S. 871 , 99 S.Ct. 203 , 58 L.Ed.2d 183 (1978))); see also United States v. Simmons, 536 F.2d 827, 831-32 (9th Cir.) (“Conclusory allegations of general anxiety and depression are present in almost every criminal prosecution.

11994–1994
State v. Murphy green
haw · 1978
1 sentence

1980State v. Murphy, supra at 6 , 575 P.2d at 453 . 4 Appellant does not raise a speedy trial violation for the period from arrest to trial or indictment to trial. 5 The following cases hold that the delay between arrest and indictment did not violate the right to speedy trial.

11980–1980

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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