Barker factors (Kansas) · Go Syfert
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Barker factors in Kansas

42 Kansas opinions name it 2 courts 1979–2026 12 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 (23)

CaseFollowedCited
Barker v. Wingogreen
scotus · 1972 · cited in 14 Kansas opinions naming this issue, 1998–2026
2 sentences

2022Yet the Barker factors are nonexclusive, 407 U.S. at 530 , and our speedy trial assessment considers totality of the circumstances.

2022Yet the Barker factors are nonexclusive, 407 U.S. at 530 , and our speedy trial assessment considers totality of the circumstances.

514
State v. Davisgreen
kan · 2004 · cited in 4 Kansas opinions naming this issue, 2019–2026
2 sentences

2026Until the delay rises to the level of being presumptively prejudicial, it is not necessary to inquire into the other Barker factors." State v. Davis, 277 Kan. 309, 334 , 85 P.3d 1164 (2004).

2026Until the delay rises to the level of being presumptively prejudicial, it is not necessary to inquire into the other Barker factors." State v. Davis, 277 Kan. 309, 334 , 85 P.3d 1164 (2004).

24
State v. Owensgreen
kan · 2019 · cited in 4 Kansas opinions naming this issue, 2020–2025
2 sentences

2025See State v. Owens, 310 Kan. 865 , 871-81, 451 P.3d 467 (2019) (applying the Barker factors to state and federal constitutional speedy trial claims).

2025See State v. Owens, 310 Kan. 865 , 871-81, 451 P.3d 467 (2019) (applying the Barker factors to state and federal constitutional speedy trial claims).

24
State v. Fitchgreen
kan · 1991 · cited in 4 Kansas opinions naming this issue, 1991–2024
2 sentences

2016Cir. 2006) (reviewing "the district court's factual findings for clear error and its application of the Barker factors to the facts de novo"); State v. Fitch, 249 Kan. 562, 565 , 819 P.2d 1225 (1991) (noting trial court concluded reason for delay was "more neutral" than deliberate hampering of defense and therefore weighed less heavily against State, and that "the record amply supports that finding").

2016Cir. 2006) (reviewing "the district court's factual findings for clear error and its application of the Barker factors to the facts de novo"); State v. Fitch, 249 Kan. 562, 565 , 819 P.2d 1225 (1991) (noting trial court concluded reason for delay was "more neutral" than deliberate hampering of defense and therefore weighed less heavily against State, and that "the record amply supports that finding").

24
State v. Oterogreen
kan · 1972 · cited in 3 Kansas opinions naming this issue, 1991–2018
2 sentences

2018See State v. Otero , 210 Kan. 530 , 532-33, 502 P.2d 763 (1972) (adopting Barker test in Kansas).

2018See State v. Otero , 210 Kan. 530 , 532-33, 502 P.2d 763 (1972) (adopting Barker test in Kansas).

23
State v. Rosinegreen
kan · 1983 · cited in 3 Kansas opinions naming this issue, 1985–1991
2 sentences

1991See, e.g., State v. Rosine, 233 Kan. at 666.

1985In State v. Rosine, 233 Kan. 663 , it was held that in each case a court must balance the action or inaction of the State with that of the accused and consider the four Barker factors, including the length of the delay, defendant’s assertion of his right to a speedy trial, the reason for the delay, and the prejudice resulting to the defendant.

23
State v. Riveragreen
kan · 2004 · cited in 5 Kansas opinions naming this issue, 2006–2022
2 sentences

2006Sixth Amendment Speedy Trial Analysis Our Supreme Court adopted the four-part Barker test for violations of the constitutional right to a speedy trial in Rivera, 277 Kan. at 113 .

2006Sixth Amendment Speedy Trial Analysis Our Supreme Court adopted the four-part Barker test for violations of the constitutional right to a speedy trial in Rivera, 277 Kan. at 113 .

15
State v. Weavergreen
kan · 2003 · cited in 5 Kansas opinions naming this issue, 2004–2020
2 sentences

2006This court found that this was an intolerable delay, but, after considering the other Barker factors, held that Weaver's constitutional right to a speedy trial was not violated. 276 Kan. at 512 .

2006This court found that this was an intolerable delay, but, after considering the other Barker factors, held that Weaver's constitutional right to a speedy trial was not violated. 276 Kan. at 512 .

15
State v. Haydengreen
kan · 2006 · cited in 3 Kansas opinions naming this issue, 2016–2026
2 sentences

2026State v. Ford, 316 Kan. 558 , 561, 519 P.3d 456 (2022); State v. Hayden, 281 Kan. 112, 127 , 130 P.3d 24 (2006) (observing this court adopted Barker factors in Otero).

2026State v. Ford, 316 Kan. 558 , 561, 519 P.3d 456 (2022); State v. Hayden, 281 Kan. 112, 127 , 130 P.3d 24 (2006) (observing this court adopted Barker factors in Otero).

13
State v. Greengreen
kan · 1996 · cited in 3 Kansas opinions naming this issue, 1997–2006
2 sentences

1997We discussed the Barker test in Green, 260 Kan. at 473-74 .

1997We discussed the Barker test in Green, 260 Kan. at 473-74 .

13
Harris v. Ron Championgreen
ca10 · 1994 · cited in 2 Kansas opinions naming this issue, 2008–2015
2 sentences

2015Those four factors, known as the Barker test, are: (1) the length of the delay; (2) tire reason for the delay; (3) the defendant’s assertion of his or her right; and (4) prejudice to the defendant. 15 F.3d at 1559 (adopting factors from Barker, 407 U.S. at 530 ).

2015Those four factors, known as the Barker test, are: (1) the length of the delay; (2) tire reason for the delay; (3) the defendant’s assertion of his or her right; and (4) prejudice to the defendant. 15 F.3d at 1559 (adopting factors from Barker, 407 U.S. at 530 ).

12
State v. Manngreen
kan · 2002 · cited in 2 Kansas opinions naming this issue, 2004–2006
2 sentences

2006We have also held that, "[u]ntil the delay rises to the level of being presumptively prejudicial, it is not necessary to inquire into the other Barker factors." State v. Mann, 274 Kan. 670, 701 , 56 P.3d 212 (2002).

2006We have also held that, "[u]ntil the delay rises to the level of being presumptively prejudicial, it is not necessary to inquire into the other Barker factors." State v. Mann, 274 Kan. 670, 701 , 56 P.3d 212 (2002).

12
State v. Finkgreen
kan · 1975 · cited in 2 Kansas opinions naming this issue, 1979–2004
2 sentences

1979Perhaps the most complete analysis of the Barker factors to be found in the Kansas cases is in State v. Fink, 217 Kan. at 678-679 .

1979Perhaps the most complete analysis of the Barker factors to be found in the Kansas cases is in State v. Fink, 217 Kan. at 678-679 .

12
United States v. Ghailanigreen
ca2 · 2013 · cited in 1 Kansas opinions naming this issue, 2016–2016
11
United States v. Tchibassa, Arturgreen
cadc · 2006 · cited in 1 Kansas opinions naming this issue, 2016–2016
11
United States v. Molina-Soloriogreen
ca5 · 2009 · cited in 1 Kansas opinions naming this issue, 2016–2016
11
State v. Friberggreen
minn · 1989 · cited in 1 Kansas opinions naming this issue, 2016–2016
11
State v. Walkergreen
kan · 2016 · cited in 1 Kansas opinions naming this issue, 2016–2016
11
Joshua Hurst v. State of Mississippigreen
miss · 2016 · cited in 1 Kansas opinions naming this issue, 2016–2016
2 sentences

2016See United States v. Ghailani, 733 F.3d 29 , 30 44 (2d Cir. 2013) (recognizing that although other panels in the Second Circuit had previously used an abuse of discretion standard, "a district court is in no better position than a reviewing court to undertake the required balancing"); People v. Crane, 195 Ill. 2d 42, 51-52 , 743 N.E.2d 555 (2001) (reasoning that because the trial court is in no better position than the reviewing court to apply the Barker factors, appellate courts should review a defendant's constitutional speedy trial challenge de novo); see also Hurst v. State, 195 So. 3d 736

2016See United States v. Ghailani, 733 F.3d 29 , 30 44 (2d Cir. 2013) (recognizing that although other panels in the Second Circuit had previously used an abuse of discretion standard, "a district court is in no better position than a reviewing court to undertake the required balancing"); People v. Crane, 195 Ill. 2d 42, 51-52 , 743 N.E.2d 555 (2001) (reasoning that because the trial court is in no better position than the reviewing court to apply the Barker factors, appellate courts should review a defendant's constitutional speedy trial challenge de novo); see also Hurst v. State, 195 So. 3d 736

11
State v. Pierregreen
lactapp · 2014 · cited in 1 Kansas opinions naming this issue, 2016–2016
11
Morel v. Wilkinsgreen
fla · 2012 · cited in 1 Kansas opinions naming this issue, 2015–2015
11
State v. Matheniagreen
kan · 1997 · cited in 1 Kansas opinions naming this issue, 2003–2003
11
State v. Smithgreen
kan · 2001 · cited in 1 Kansas opinions naming this issue, 2003–2003
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (26)

CaseCitedYears
United States v. Marion green
scotus · 1971
2 sentences

2012Reason for the Delay In Barker, 404 U.S. at 531 , the Supreme Court stated drat “different weights should be assigned to different reasons” for the delay in bringing a defendant to trial: “A deliberate attempt to delay the trial in order to hamper the defense should be weighted heavily against the government.

2012Reason for the Delay In Barker, 404 U.S. at 531 , the Supreme Court stated drat “different weights should be assigned to different reasons” for the delay in bringing a defendant to trial: “A deliberate attempt to delay the trial in order to hamper the defense should be weighted heavily against the government.

22002–2012
State v. Goss green
kan · 1989
2 sentences

2003State v. Goss, 245 Kan. 189, 193 , 777 P.2d 781 [1989], We find that, clearly, a 14-month delay qualifies as ‘a little over a year,’ thereby negating further analysis of other Barker factors.”).

2003State v. Goss, 245 Kan. 189, 193 , 777 P.2d 781 [1989], We find that, clearly, a 14-month delay qualifies as ‘a little over a year,’ thereby negating further analysis of other Barker factors.”).

22003–2006
State v. Hill green
kan · 1995
2 sentences

2006See Mann, 274 Kan. at 701 ; see also State v. Green, 260 Kan. 471 , 920 P.2d 414 (1996) (15 months between filing of complaint, trial; 1-year delay between arraignment, trial; no presumptive prejudice); State v. Hill, 257 Kan. 774, 779 , 895 P.2d 1238 (1995) (less than 11-month delay not presumptively prejudicial); State v. Goss, 245 Kan. 189, 193 , 777 P.2d 781 (slightly more than 1-year delay not presumptively prejudicial). *128 We have resisted using our previous cases to set a specific time limit.

2006See Mann, 274 Kan. at 701 ; see also State v. Green, 260 Kan. 471 , 920 P.2d 414 (1996) (15 months between filing of complaint, trial; 1-year delay between arraignment, trial; no presumptive prejudice); State v. Hill, 257 Kan. 774, 779 , 895 P.2d 1238 (1995) (less than 11-month delay not presumptively prejudicial); State v. Goss, 245 Kan. 189, 193 , 777 P.2d 781 (slightly more than 1-year delay not presumptively prejudicial). *128 We have resisted using our previous cases to set a specific time limit.

22002–2006
State v. Ruff green
kan · 1998
2 sentences

2003Unless we find the delay in this case to be presumptively prejudicial, there is no need to inquire further into the other factors in the Barker analysis. 266 Kan. at 32 ; see State v. Smith, 271 Kan. 666, 682 , 24 P.3d 727 (2001).

2003Unless we find the delay in this case to be presumptively prejudicial, there is no need to inquire further into the other factors in the Barker analysis. 266 Kan. at 32 ; see State v. Smith, 271 Kan. 666, 682 , 24 P.3d 727 (2001).

22002–2003
State v. Hunt green
kanctapp · 1982
2 sentences

1985E.g., State v. Calderon, 233 Kan. 87, 94 , 661 P.2d 781 (1983); State v. Hunt, 8 Kan.

1985E.g., State v. Calderon, 233 Kan. 87, 94 , 661 P.2d 781 (1983); State v. Hunt, 8 Kan.

21983–1985
State v. Calderon green
kan · 1983
2 sentences

1985E.g., State v. Calderon, 233 Kan. 87, 94 , 661 P.2d 781 (1983); State v. Hunt, 8 Kan.

1985E.g., State v. Calderon, 233 Kan. 87, 94 , 661 P.2d 781 (1983); State v. Hunt, 8 Kan.

21983–1985
Doggett v. United States green
scotus · 1992
2 sentences

2026The length of the delay When reviewing the length of the delay, we first determine "whether the relevant interval [between the filing of charges and trial] 'has crossed the threshold dividing ordinary from presumptively prejudicial delay.'" Cherry, 320 Kan. at 800 (citing Doggett v. United States, 505 U.S. 647, 651-52 , 112 S. Ct. 2686 , 120 L.

2026The length of the delay When reviewing the length of the delay, we first determine "whether the relevant interval [between the filing of charges and trial] 'has crossed the threshold dividing ordinary from presumptively prejudicial delay.'" Cherry, 320 Kan. at 800 (citing Doggett v. United States, 505 U.S. 647, 651-52 , 112 S. Ct. 2686 , 120 L.

12026–2026
United States v. Loud Hawk green
scotus · 1986
2 sentences

2026The reason for the delay The second factor is known as the "'flag all litigants seek to capture.'" Cherry, 320 Kan. at 801 (quoting United States v. Loud Hawk, 474 U.S. 302, 315 , 106 S. Ct. 648 , 88 L.

2026The reason for the delay The second factor is known as the "'flag all litigants seek to capture.'" Cherry, 320 Kan. at 801 (quoting United States v. Loud Hawk, 474 U.S. 302, 315 , 106 S. Ct. 648 , 88 L.

12026–2026
State v. McDonald green
kanctapp · 2022
1 sentence

2024Owens, 310 Kan. at 869; State v. McDonald, 62 Kan.

12024–2024
State v. Moncla green
kan · 2000
2 sentences

2024The State points to State v. Moncla, 269 Kan. 61, 65 , 4 P.3d 618 (2000), where the Kansas Supreme Court found the district court's approach impeded appellate review because it did not state its findings or conclusions of law.

2024The State points to State v. Moncla, 269 Kan. 61, 65 , 4 P.3d 618 (2000), where the Kansas Supreme Court found the district court's approach impeded appellate review because it did not state its findings or conclusions of law.

12024–2024
State v. Queen green
kan · 2021
2 sentences

2022State v. Queen, 313 Kan. 12 , 16, 482 P.3d 1117 (2021) ("[Defendant] has not argued . . . that he could meet his burden to establish any of [the Barker] factors".).

2022State v. Queen, 313 Kan. 12 , 16, 482 P.3d 1117 (2021) ("[Defendant] has not argued . . . that he could meet his burden to establish any of [the Barker] factors".).

12022–2022
State v. Taylor green
kanctapp · 1979
2 sentences

2022The Sixth Amendment to the United States Constitution grants every defendant the "right to a speedy and public trial." Similarly, section 10 of the Kansas Constitution Bill of Rights guarantees Kansas defendants "[i]n all prosecutions . . . a speedy public trial by an impartial jury." See Owens, 310 Kan. at 869. "'The constitutional protection of a speedy trial attaches when one becomes accused and the criminal prosecution begins, usually by either an indictment, an information, or an arrest, whichever first occurs.' State v. Taylor, 3 Kan.

2022The Sixth Amendment to the United States Constitution grants every defendant the "right to a speedy and public trial." Similarly, section 10 of the Kansas Constitution Bill of Rights guarantees Kansas defendants "[i]n all prosecutions . . . a speedy public trial by an impartial jury." See Owens, 310 Kan. at 869. "'The constitutional protection of a speedy trial attaches when one becomes accused and the criminal prosecution begins, usually by either an indictment, an information, or an arrest, whichever first occurs.' State v. Taylor, 3 Kan.

12022–2022
State v. Vaughn green
kan · 1993
2 sentences

2020Vaughn, 254 Kan. at 195-96 .

2020Vaughn, 254 Kan. at 195-96 .

12020–2020
State v. Rizal green
kan · 2019
2 sentences

2020And "it is not our job to engage in fact-finding." State v. Rizal, 310 Kan. 199 , 204, 445 P.3d 734 (2019).

2020And "it is not our job to engage in fact-finding." State v. Rizal, 310 Kan. 199 , 204, 445 P.3d 734 (2019).

12020–2020
State v. Bloom green
kan · 2002
2 sentences

2019The State in this case largely blurs the distinction between the first and second Barker factors, suggesting this court did so in 11 State v. Davis, 277 Kan. 309 , 85 P.3d 1164 (2004), State v. Bloom, 273 Kan. 291 , 44 P.3d 305 (2002), and State v. Smallwood, 264 Kan. 69 , 955 P.2d 1209 (1998).

2019The State in this case largely blurs the distinction between the first and second Barker factors, suggesting this court did so in 11 State v. Davis, 277 Kan. 309 , 85 P.3d 1164 (2004), State v. Bloom, 273 Kan. 291 , 44 P.3d 305 (2002), and State v. Smallwood, 264 Kan. 69 , 955 P.2d 1209 (1998).

12019–2019
State v. Smallwood green
kan · 1998
2 sentences

2019The State in this case largely blurs the distinction between the first and second Barker factors, suggesting this court did so in 11 State v. Davis, 277 Kan. 309 , 85 P.3d 1164 (2004), State v. Bloom, 273 Kan. 291 , 44 P.3d 305 (2002), and State v. Smallwood, 264 Kan. 69 , 955 P.2d 1209 (1998).

2019The State in this case largely blurs the distinction between the first and second Barker factors, suggesting this court did so in 11 State v. Davis, 277 Kan. 309 , 85 P.3d 1164 (2004), State v. Bloom, 273 Kan. 291 , 44 P.3d 305 (2002), and State v. Smallwood, 264 Kan. 69 , 955 P.2d 1209 (1998).

12019–2019
State v. Mossman green
kan · 2012
12016–2016
State v. Porter green
ga · 2011
12016–2016
People v. Crane green
ill · 2001
12016–2016
State v. Selvage green
ohio · 1997
12016–2016
In Re the Care & Treatment of Ellison green
kanctapp · 2015
12016–2016
Lamb green
mass · 1975
12015–2015
People v. Litmon green
calctapp · 2008
12015–2015
State v. Bussart-Savaloja green
kanctapp · 2008
12015–2015
United States v. William John Yehling green
ca10 · 2006
12008–2008
State v. Galloway green
kan · 1982
11985–1985

Statutes the citing opinions construe

KS § K.S.A. § 22-3402 (28) KS § K.S.A. § 22-3201 (4) KS § K.S.A. § 60-404 (4) KS § K.S.A. § 60-455 (4) KS § K.S.A. § 21-3401 (3) KS § K.S.A. § 22-2901 (3) KS § K.S.A. § 22-2902 (3) KS § K.S.A. § 22-3208 (3) KS § K.S.A. § 22-3601 (3) KS § K.S.A. § 59-29a01 (3) KS § K.S.A. § 59-29a06 (3) KS § K.S.A. § 60-460 (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 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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