Ruffin v. State

Summary

The court affirmed the denial of Ruffin's motion to dismiss the indictment for violation of his constitutional speedy-trial rights. Applying the two-stage presumptive-prejudice and four-factor balancing framework, the court held that the delay was presumptively prejudicial and that several aspects of the trial court's analysis were erroneous, but concluded that the trial court did not abuse its discretion because Ruffin did not establish persuasive prejudice and asserted his right relatively late. The court warned that any further delay not attributable to Ruffin could require dismissal. No separate opinions were filed.