Barker test (Alaska) · Go Syfert
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Barker test in Alaska

6 Alaska opinions name it 2 courts 1991–2024 1 in the last five years

The cases below were cited by Alaska 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 (9)

CaseFollowedCited
Barker v. Wingogreen
scotus · 1972 · cited in 2 Alaska opinions naming this issue, 2017–2017
2 sentences

2017KING & ORIN S. KERR, CRIMINAL PROCEDURE § 18.1(c), at 110 (3d ed. 2007)). 10 Id. at 1006. 11 Id. 12 Id. at 1006-07. 13 806 P.2d 330 (Alaska App. 1991). 14 546 P.2d 564 (Alaska 1976). -7- 7200 Turning to the trial court’s decision, the court of appeals found that the trial court had misapplied the four-factor Barker test.15 According to the court of appeals, the trial court erred in finding Wright partially responsible for the delay because after he left Alaska he “was not hiding out, and the State had avenues of locating him” that likely would have been productive.16 Further, the trial court s

2017KING & ORIN S. KERR, CRIMINAL PROCEDURE § 18.1(c), at 110 (3d ed. 2007)). 10 Id. at 1006. 11 Id. 12 Id. at 1006-07. 13 806 P.2d 330 (Alaska App. 1991). 14 546 P.2d 564 (Alaska 1976). -7- 7200 Turning to the trial court’s decision, the court of appeals found that the trial court had misapplied the four-factor Barker test.15 According to the court of appeals, the trial court erred in finding Wright partially responsible for the delay because after he left Alaska he “was not hiding out, and the State had avenues of locating him” that likely would have been productive.16 Further, the trial court s

22
State v. Mousergreen
alaskactapp · 1991 · cited in 3 Alaska opinions naming this issue, 2017–2024
2 sentences

2024We will require the defendant to demonstrate prejudice in order to prevail.”). –6– 2772 But this Court adopted the Barker test in State v. Mouser.21 And as various commentators have explained, deducting the time attributable to the defendant for purposes of this initial threshold inquiry is inconsistent with the Barker test, which treats the reason for the delay as a separate factor to be considered if (and only if) the initial threshold under the first factor is met.22 For example, in his treatise on criminal procedure, Professor LaFave has explained: Some lower courts apply the first Barker

2024We will require the defendant to demonstrate prejudice in order to prevail.”). –6– 2772 But this Court adopted the Barker test in State v. Mouser.21 And as various commentators have explained, deducting the time attributable to the defendant for purposes of this initial threshold inquiry is inconsistent with the Barker test, which treats the reason for the delay as a separate factor to be considered if (and only if) the initial threshold under the first factor is met.22 For example, in his treatise on criminal procedure, Professor LaFave has explained: Some lower courts apply the first Barker

13
Caterpillar Tractor Co. v. Beckgreen
alaska · 1979 · cited in 2 Alaska opinions naming this issue, 1991–2007
2 sentences

2007See discussion of the Barker test in Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880-86 (Alaska 1979). [36] Martech, 852 P.2d at 1149 n. 7 (citation omitted); see also Meyer v. State, 994 P.2d 365, 367 (Alaska 1999). [37] Martech, 852 P.2d at 1149 n. 7 (citation omitted). [38] Collateral estoppel, also known as issue preclusion, "is the doctrine that prevents the relitigation of an issue that was actually litigated and was a critical and necessary part of the earlier judgment.

2007See discussion of the Barker test in Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880-86 (Alaska 1979). [36] Martech, 852 P.2d at 1149 n. 7 (citation omitted); see also Meyer v. State, 994 P.2d 365, 367 (Alaska 1999). [37] Martech, 852 P.2d at 1149 n. 7 (citation omitted). [38] Collateral estoppel, also known as issue preclusion, "is the doctrine that prevents the relitigation of an issue that was actually litigated and was a critical and necessary part of the earlier judgment.

12
Davis v. Stategreen
alaskactapp · 2006 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024LaFave et al., Criminal Procedure §18.2(b), at 130-32 (4th ed. 2015); State v. Serros, 366 P.3d 1121 , 1131 (N.M. 2015) (holding that the parties’ fault in causing the delay is irrelevant to the analysis of the first Barker factor). 23 LaFave, Criminal Procedure §18.2(b), at 132 (citation omitted). 24 See Mouser, 860 P.2d at 336, 339-41; Wright, 404 P.3d at 178 . 25 See, e.g., Alvarez v. Ketchikan Gateway Borough, 91 P.3d 289, 294-95 (Alaska App. 2004); Davis v. State, 133 P.3d 719, 725 (Alaska App. 2006); Tix v. State, 2011 WL 2437680 , at *4 (Alaska App. June 15, 2011) (unpublished); Sage v.

2024LaFave et al., Criminal Procedure §18.2(b), at 130-32 (4th ed. 2015); State v. Serros, 366 P.3d 1121 , 1131 (N.M. 2015) (holding that the parties’ fault in causing the delay is irrelevant to the analysis of the first Barker factor). 23 LaFave, Criminal Procedure §18.2(b), at 132 (citation omitted). 24 See Mouser, 860 P.2d at 336, 339-41; Wright, 404 P.3d at 178 . 25 See, e.g., Alvarez v. Ketchikan Gateway Borough, 91 P.3d 289, 294-95 (Alaska App. 2004); Davis v. State, 133 P.3d 719, 725 (Alaska App. 2006); Tix v. State, 2011 WL 2437680 , at *4 (Alaska App. June 15, 2011) (unpublished); Sage v.

11
Braithwaite v. West Valley City Corp.green
utah · 1993 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024LaFave et al., Criminal Procedure §18.2(b), at 130-32 (4th ed. 2015); State v. Serros, 366 P.3d 1121 , 1131 (N.M. 2015) (holding that the parties’ fault in causing the delay is irrelevant to the analysis of the first Barker factor). 23 LaFave, Criminal Procedure §18.2(b), at 132 (citation omitted). 24 See Mouser, 860 P.2d at 336, 339-41; Wright, 404 P.3d at 178 . 25 See, e.g., Alvarez v. Ketchikan Gateway Borough, 91 P.3d 289, 294-95 (Alaska App. 2004); Davis v. State, 133 P.3d 719, 725 (Alaska App. 2006); Tix v. State, 2011 WL 2437680 , at *4 (Alaska App. June 15, 2011) (unpublished); Sage v.

2024LaFave et al., Criminal Procedure §18.2(b), at 130-32 (4th ed. 2015); State v. Serros, 366 P.3d 1121 , 1131 (N.M. 2015) (holding that the parties’ fault in causing the delay is irrelevant to the analysis of the first Barker factor). 23 LaFave, Criminal Procedure §18.2(b), at 132 (citation omitted). 24 See Mouser, 860 P.2d at 336, 339-41; Wright, 404 P.3d at 178 . 25 See, e.g., Alvarez v. Ketchikan Gateway Borough, 91 P.3d 289, 294-95 (Alaska App. 2004); Davis v. State, 133 P.3d 719, 725 (Alaska App. 2006); Tix v. State, 2011 WL 2437680 , at *4 (Alaska App. June 15, 2011) (unpublished); Sage v.

11
State v. Wrightgreen
alaska · 2017 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024We will require the defendant to demonstrate prejudice in order to prevail.”). –6– 2772 But this Court adopted the Barker test in State v. Mouser.21 And as various commentators have explained, deducting the time attributable to the defendant for purposes of this initial threshold inquiry is inconsistent with the Barker test, which treats the reason for the delay as a separate factor to be considered if (and only if) the initial threshold under the first factor is met.22 For example, in his treatise on criminal procedure, Professor LaFave has explained: Some lower courts apply the first Barker

2024We will require the defendant to demonstrate prejudice in order to prevail.”). –6– 2772 But this Court adopted the Barker test in State v. Mouser.21 And as various commentators have explained, deducting the time attributable to the defendant for purposes of this initial threshold inquiry is inconsistent with the Barker test, which treats the reason for the delay as a separate factor to be considered if (and only if) the initial threshold under the first factor is met.22 For example, in his treatise on criminal procedure, Professor LaFave has explained: Some lower courts apply the first Barker

11
Alvarez v. Ketchikan Gateway Boroughgreen
alaskactapp · 2004 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024LaFave et al., Criminal Procedure §18.2(b), at 130-32 (4th ed. 2015); State v. Serros, 366 P.3d 1121 , 1131 (N.M. 2015) (holding that the parties’ fault in causing the delay is irrelevant to the analysis of the first Barker factor). 23 LaFave, Criminal Procedure §18.2(b), at 132 (citation omitted). 24 See Mouser, 860 P.2d at 336, 339-41; Wright, 404 P.3d at 178 . 25 See, e.g., Alvarez v. Ketchikan Gateway Borough, 91 P.3d 289, 294-95 (Alaska App. 2004); Davis v. State, 133 P.3d 719, 725 (Alaska App. 2006); Tix v. State, 2011 WL 2437680 , at *4 (Alaska App. June 15, 2011) (unpublished); Sage v.

2024LaFave et al., Criminal Procedure §18.2(b), at 130-32 (4th ed. 2015); State v. Serros, 366 P.3d 1121 , 1131 (N.M. 2015) (holding that the parties’ fault in causing the delay is irrelevant to the analysis of the first Barker factor). 23 LaFave, Criminal Procedure §18.2(b), at 132 (citation omitted). 24 See Mouser, 860 P.2d at 336, 339-41; Wright, 404 P.3d at 178 . 25 See, e.g., Alvarez v. Ketchikan Gateway Borough, 91 P.3d 289, 294-95 (Alaska App. 2004); Davis v. State, 133 P.3d 719, 725 (Alaska App. 2006); Tix v. State, 2011 WL 2437680 , at *4 (Alaska App. June 15, 2011) (unpublished); Sage v.

11
Martech Construction Co. v. Ogden Environmental Services, Inc.green
alaska · 1993 · cited in 1 Alaska opinions naming this issue, 2007–2007
2 sentences

2007See discussion of the Barker test in Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880-86 (Alaska 1979). [36] Martech, 852 P.2d at 1149 n. 7 (citation omitted); see also Meyer v. State, 994 P.2d 365, 367 (Alaska 1999). [37] Martech, 852 P.2d at 1149 n. 7 (citation omitted). [38] Collateral estoppel, also known as issue preclusion, "is the doctrine that prevents the relitigation of an issue that was actually litigated and was a critical and necessary part of the earlier judgment.

2007See discussion of the Barker test in Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880-86 (Alaska 1979). [36] Martech, 852 P.2d at 1149 n. 7 (citation omitted); see also Meyer v. State, 994 P.2d 365, 367 (Alaska 1999). [37] Martech, 852 P.2d at 1149 n. 7 (citation omitted). [38] Collateral estoppel, also known as issue preclusion, "is the doctrine that prevents the relitigation of an issue that was actually litigated and was a critical and necessary part of the earlier judgment.

11
Meyer v. State, Department of Revenue, Child Support Enforcement Division Ex Rel. N.G.T.green
alaska · 1999 · cited in 1 Alaska opinions naming this issue, 2007–2007
2 sentences

2007See discussion of the Barker test in Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880-86 (Alaska 1979). [36] Martech, 852 P.2d at 1149 n. 7 (citation omitted); see also Meyer v. State, 994 P.2d 365, 367 (Alaska 1999). [37] Martech, 852 P.2d at 1149 n. 7 (citation omitted). [38] Collateral estoppel, also known as issue preclusion, "is the doctrine that prevents the relitigation of an issue that was actually litigated and was a critical and necessary part of the earlier judgment.

2007See discussion of the Barker test in Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880-86 (Alaska 1979). [36] Martech, 852 P.2d at 1149 n. 7 (citation omitted); see also Meyer v. State, 994 P.2d 365, 367 (Alaska 1999). [37] Martech, 852 P.2d at 1149 n. 7 (citation omitted). [38] Collateral estoppel, also known as issue preclusion, "is the doctrine that prevents the relitigation of an issue that was actually litigated and was a critical and necessary part of the earlier judgment.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Yarbor v. State green
alaska · 1976
2 sentences

2017KING & ORIN S. KERR, CRIMINAL PROCEDURE § 18.1(c), at 110 (3d ed. 2007)). 10 Id. at 1006. 11 Id. 12 Id. at 1006-07. 13 806 P.2d 330 (Alaska App. 1991). 14 546 P.2d 564 (Alaska 1976). -7- 7200 Turning to the trial court’s decision, the court of appeals found that the trial court had misapplied the four-factor Barker test.15 According to the court of appeals, the trial court erred in finding Wright partially responsible for the delay because after he left Alaska he “was not hiding out, and the State had avenues of locating him” that likely would have been productive.16 Further, the trial court s

2017KING & ORIN S. KERR, CRIMINAL PROCEDURE § 18.1(c), at 110 (3d ed. 2007)). 10 Id. at 1006. 11 Id. 12 Id. at 1006-07. 13 806 P.2d 330 (Alaska App. 1991). 14 546 P.2d 564 (Alaska 1976). -7- 7200 Turning to the trial court’s decision, the court of appeals found that the trial court had misapplied the four-factor Barker test.15 According to the court of appeals, the trial court erred in finding Wright partially responsible for the delay because after he left Alaska he “was not hiding out, and the State had avenues of locating him” that likely would have been productive.16 Further, the trial court s

22017–2017
Doggett v. United States green
scotus · 1992
2 sentences

2024Under this prior case law, the total length of delay is immaterial.17 Instead, to determine whether the length of delay qualifies as presumptively prejudicial, the delay that is attributable to the defendant is subtracted from the total length of delay.18 If the remaining length of delay is more than fourteen months, Alaska courts have treated the delay as “presumptively prejudicial” for purposes of the Alaska constitution’s speedy trial right.19 If the remaining length of delay is less than eight months, the defendant must demonstrate actual prejudice.20 15 Id. at 652 n.1.

2024Under this prior case law, the total length of delay is immaterial.17 Instead, to determine whether the length of delay qualifies as presumptively prejudicial, the delay that is attributable to the defendant is subtracted from the total length of delay.18 If the remaining length of delay is more than fourteen months, Alaska courts have treated the delay as “presumptively prejudicial” for purposes of the Alaska constitution’s speedy trial right.19 If the remaining length of delay is less than eight months, the defendant must demonstrate actual prejudice.20 15 Id. at 652 n.1.

12024–2024
Brown v. Superior Court green
cal · 1988
2 sentences

1992While the social utility and value of prescription drugs as a class of products may exceed that of most other classes of products, we do not believe that this generalization warrants granting “the same protection from liability to those who gave us thalidomide as to the producers of penicillin.” 245 Cal.Rptr. at 423 , 751 P.2d at 481 .

1992While the social utility and value of prescription drugs as a class of products may exceed that of most other classes of products, we do not believe that this generalization warrants granting “the same protection from liability to those who gave us thalidomide as to the producers of penicillin.” 245 Cal.Rptr. at 423 , 751 P.2d at 481 .

11992–1992

Where else courts name it

TX 479 (1995–2026) MS 238 (1986–2026) NM 227 (1987–2026) GA 146 (1976–2026) OH 129 (1985–2026) TN 91 (1987–2026) AL 75 (1977–2026) CA 69 (1980–2026) LA 68 (1983–2025) NJ 47 (1999–2026) WA 45 (2009–2026) KS 42 (1979–2026) NC 41 (1993–2026) MI 40 (2006–2026) MT 40 (1975–2020) IL 39 (1989–2025) ID 38 (1981–2025) WY 38 (1989–2023) IN 32 (1980–2020) MO 29 (1979–2025) DE 28 (1987–2026) PA 28 (1976–2025) MN 27 (1986–2025) MD 26 (1975–2024) CO 25 (1975–2026) KY 23 (1978–2024) VT 21 (1983–2025) VA 19 (1990–2025) RI 18 (1967–2015) WI 17 (1990–2026) UT 16 (1986–2026) NH 16 (1985–2022) AZ 16 (1982–2026) HI 14 (1981–2025) DC 13 (1977–2012) FL 12 (1982–2024) ME 11 (1981–2025) MA 9 (1982–2025) SC 9 (2009–2026) VI 8 (2010–2026) CT 8 (1987–2018) OR 8 (1977–2021) ND 8 (1994–2021) NV 8 (1983–2020) AK 6 (1991–2024) NE 5 (1999–2019) OK 5 (1994–2023) SD 3 (1994–2026) IA 3 (2001–2019) NY 3 (1896–2018) AR 2 (2004–2023)

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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