State of New Mexico, Plaintiff-Petitioner v. Frank O. Garza, Defendant-Respondent

Summary

The Court held that a delay deemed presumptively prejudicial merely triggers analysis of the four speedy-trial factors and does not itself establish a constitutional violation. Applying that approach, the Court concluded that Garza’s approximately ten-month delay, slight negligent delay, limited assertion of the right, and failure to show particularized prejudice did not support dismissal. The Court also adopted new presumptive-delay guidelines of twelve months for simple cases, fifteen months for intermediate cases, and eighteen months for complex cases. No separate opinions were filed.