State of Montana, Plaintiff and Respondent v. Kingsley Ariegwe, Defendant and Appellant

Summary

The court revised Montana's framework for evaluating speedy-trial claims, replacing the prior burden-shifting approach with a case-specific balancing of four factors: delay length, reasons for delay, the accused's responses, and prejudice. It reaffirmed a 200-day threshold for triggering review, adopted an intensifying presumption of prejudice, assigned the State the burden of explaining delays, and required trial courts to make findings and conclusions on each factor. The visible portion states that the judgment was affirmed in part, reversed in part, and remanded for further proceedings. Justice Rice, joined by Justices Morris, Leaphart, and Warner, concurred while criticizing the complexity of the revised test.