Limmie Daniel Phillips, Jr., Appellant v. the State of Texas, Appellee

Summary

The Court held that the seventeen‑month delay between indictment and trial, coupled with the State's negligent failure to notify the appellant, violated his Sixth Amendment right to a speedy trial, and therefore reversed the conviction and ordered dismissal of the prosecution. The Court emphasized that negligence, while less culpable than intentional delay, still requires a remedy, and that the appellant showed sufficient prejudice. Justice Dally dissented, arguing the prejudice was overstated and the prosecution should not be dismissed.