Cited by

that could be construed as the assertion of the speedy trial right.”

9 “[t]he right to a speedy trial is as fundamental as any of the rights secured by the Sixth Amendment.” (quotations omitted).

(“Normally, the unavailability of a witness constitutes good cause for delay.”).

State v. Windish , (adopting test established in Barker v. Wingo, 407 U.S. 514, 530 (1972)).

(adopting test established in Barker v. Wingo, 407 U.S. 514, 530 (1972)).

Here, the district court determined that Byrd was prejudiced and suffered stress and anxiety, which was “compounded by delays in the proceedings.” See Barker v. Wingo, 407 U.S. 514, 532 (1972) (identifying the interest of “minimiz[ing] anxiety and concern” when assessing whether a defendant has suffered prejudice due to a speedy-trial violation); -19 (Minn. 1999) (applying the Barker factors).

A. Length of Delay “The length of the delay is a ‘triggering mechanism’ which determines whether further review is necessary.” (quoting Barker, 407 U.S. at 530).

“The test provides that a court must consider: (1) the length of the delay; (2) the reason for the delay; (3) whether the defendant asserted his or her right to a speedy trial; and (4) whether the delay prejudiced the defendant.” (citing Barker, 407 U.S. at 530-33).

“The test provides that a court must consider: (1) the length of the delay; (2) the reason for the delay; (3) whether the defendant asserted his or her right to a speedy trial; and (4) whether the delay prejudiced the defendant.” (citing Barker, 407 U.S. at 530-33).

“It is our duty to supervise the criminal justice system and ensure the fair administration of justice.”

-16 (Minn. 1999); see also Minn. R. Crim.

Those factors include: “(1) the length of the delay; (2) the reason for the delay; (3) whether the defendant asserted his or her right to a speedy trial; and (4) whether the delay prejudiced the defendant.” (adopting the Barker factors in Minnesota).

(stating that when deciding whether a defendant’s speedy trial right was violated, reviewing courts consider the length of the delay and prejudice).

This process requires the entire “criminal justice system, including judges, prosecutors and defense lawyers” to be “responsible for the fair administration of justice.”

We review alleged speedy-trial violations de novo, , and we consider the delay’s length, the reason for the delay, whether the defendant asserted his right to a speedy trial, and any prejudicial effect

“The length of the delay is a triggering mechanism which determines whether further review is necessary.” (quotation omitted).

d 311, 315 (Minn. 1999) (citing Barker v. Wingo, 407 U.S. 514, 530-33 (1972)).

(concluding that the first two factors do not apply when a defendant is in custody for another offense).

(citing Barker v. Wingo, 407 U.S. 514, 530 (1972)).

(citing Barker, 407 U.S. at 530-33).

A presumptively prejudicial delay triggers the “necessity for inquiry into the remaining factors of the [Barker] test.” 15 (Minn. 1999).

Under the fourth Barker factor, we consider prejudice by focusing on the defendant ’s interests in: “(1) preventing oppressive pretrial incarceration; (2) minimizing the anxiety and concern of the accused; and (3) preventing the possibility that the defense will be impaired.” d 230, 253 (Minn. 2021) ( ).

See State v. Windish , (explaining that continuances are considered under the reasons for the delay ).

In Minnesota, delays that are presump tively prejudicial trigger the “necessity for inquiry into the remaining factors of the [Barker] test.” d 311, 315 (Minn. 1999).

(citing Barker, 407 U.S. at 530).

See State v. W indish, d 311, 315-16 (Minn. 1999).

Length of the delay “In Minnesota, delays beyond 60 days from the date of demand raise a presumption that a violation [of the right to a speedy trial] has occurred.” d 311, 315–16 (Minn. 1999).

( quoting Barker, 407 U.S. at 530).

Those four factors are “(1) the length of the delay; (2) the reason for the delay; (3) whether the defendant asserted his or her right to a speedy trial; and (4) whether the delay prejudiced the defendant.” (citing Barker, 407 U.S. at 530).

State v. Windish, 13 (citing Barker, 407 U.S. at 530-33).