Joseph Leon Jenkins v. State

CourtCourt of Appeals of Texas
DecidedNovember 7, 2007
Docket10-06-00132-CR
StatusPublished

This text of Joseph Leon Jenkins v. State (Joseph Leon Jenkins v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph Leon Jenkins v. State, (Tex. Ct. App. 2007).

Opinion

IN THE

TENTH COURT OF APPEALS

 

No. 10-06-00132-CR

Joseph Leon Jenkins,

                                                                                    Appellant

 v.

The State of Texas,

                                                                                    Appellee


From the 85th District Court

Brazos County, Texas

Trial Court No. 05-01101-CRF-85

DISSENTING Opinion

Jenkins’s third issue complains of the court’s denial of his motion to dismiss for failure to provide a speedy trial, in violation of the Sixth and Fourteenth Amendments.  See Barker v. Wingo, 407 U.S. 514, 515, 530, 92 S.Ct. 2182, 2192, 33 L.Ed.2d 101 (1972).[1]  With little analysis, the majority overrules the issue.  Believing that a correct analysis of the Barker factors yields a different result, I respectfully dissent.

The right to a speedy trial was designed: (1) to prevent oppressive pretrial incarceration; (2) to minimize anxiety and concern of the defendant; and (3) to limit the possibility that the defense will be impaired.  Id. at 532, 92 S.Ct. at 2193; Shaw v. State, 117 S.W.3d 883, 890 (Tex. Crim. App. 2003).  Of these, "the most serious is the last, because the inability of a defendant adequately to prepare his case skews the fairness of the entire system."  Barker, 407 U.S. at 532, 92 S.Ct. at 2193.  If a violation of the speedy trial right is established, the only possible remedy is dismissal of the prosecution.  Dragoo v. State, 96 S.W.3d 308, 313 (Tex. Crim. App. 2003) (citing Strunk v. United States, 412 U.S. 434, 440, 93 S.Ct. 2260, 37 L.Ed.2d 56 (1973)).

Standard of Review

The Barker test has four non-exclusive factors: (1) the length of the delay; (2) the reasons for the delay; (3) the timeliness of the assertion of the right to a speedy trial; and (4) any prejudice caused by the delay.  Id.  A bifurcated standard of review applies: we review legal issues de novo but give deference to the trial court's resolution of factual issues.  Kelly v. State, 163 S.W.3d 722, 726 (Tex. Crim. App. 2005) (citing Zamorano v. State, 84 S.W.3d 643, 648 (Tex. Crim. App. 2002)).  We "must uphold the trial court's ruling if it is supported by the record and is correct under the applicable law."  Shaw, 117 S.W.3d at 889.  Applying these principles, I will examine the Barker factors in "a difficult and sensitive balancing process."  See Zamorano, 84 S.W.3d at 648 (citing Barker, 407 U.S. at 533, 92 S.Ct. at 2182).


Procedural Facts—Chronology

            The offense was alleged to have occurred on January 6, 2005.  The following events in the trial court are important in this speedy-trial inquiry.

·        Counsel was appointed by a magistrate on January 11, 2005. 

·        An indictment asserting count one was filed on February 17, 2005.

·        A second indictment, which added count two, was filed on April 21, 2005. 

·        Appointed counsel filed a motion to withdraw on May 6, 2005, which was set for hearing on June 16. 

·        On June 23, the court appointed new counsel for Jenkins. 

·        Following that appointment, trial was set for September 19. 

·        On October 24, a motion requesting a speedy trial was filed. 

·        On January 12, 2006, a pro se motion to dismiss “for lack of prosecution” was filed.

·        The motions were heard and denied on January 27, 2006.

·        The case went to trial on March 20, 2006. 

Length of Delay

            The length of delay is "a triggering mechanism" for consideration of the remaining factors.  Id. at 530, 92 S.Ct. at 2192; Shaw, 117 S.W.3d at 889; Shea v. State, 167 S.W.3d 98, 102 (Tex. App.—Waco 2005, pet. ref'd).  The delay is measured from the date of arrest or the filing of the charging instrument, whichever occurs first, to the date of trial.  Shaw, 117 S.W.3d at 889.  A delay approaching one year is sufficient to trigger the Barker review.[2]  Id.   "[T]he delay that can be tolerated for an ordinary street crime is considerably less than for a serious, complex conspiracy charge."  Whitfield v. State, 137 S.W.3d 687, 690 (Tex. App.—Waco 2007, no pet.) (quoting Barker, 407 U.S. at 531, 92 S.Ct. at 2192).

            The delay was over 12 months from Jenkins’s arrest on January 7, 2005, to the time of the hearing on the motion to dismiss and over 14 months to the time of trial.  Jenkins says this is presumptively prejudicial, the State does not seriously contest that assertion, and the majority agrees.  I believe that if the right to a speedy trial has any substance, the remaining factors must be analyzed in light of this presumptive prejudice.

Reasons for the Delay

            "The State has the burden of justifying the delay."  Shaw, 117 S.W.3d at 889 n.3.   Different weights are assigned to the various reasons for the delay asserted by the State.  Id. at 889.

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Related

Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Strunk v. United States
412 U.S. 434 (Supreme Court, 1973)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
Dragoo v. State
96 S.W.3d 308 (Court of Criminal Appeals of Texas, 2003)
Shaw v. State
117 S.W.3d 883 (Court of Criminal Appeals of Texas, 2003)
Whitfield v. State
137 S.W.3d 687 (Court of Appeals of Texas, 2004)
State v. Munoz
991 S.W.2d 818 (Court of Criminal Appeals of Texas, 1999)
Zamorano v. State
84 S.W.3d 643 (Court of Criminal Appeals of Texas, 2002)
Shea v. State
167 S.W.3d 98 (Court of Appeals of Texas, 2005)
Kelly v. State
163 S.W.3d 722 (Court of Criminal Appeals of Texas, 2005)
Meyer v. State
27 S.W.3d 644 (Court of Appeals of Texas, 2000)
Harris v. State
827 S.W.2d 949 (Court of Criminal Appeals of Texas, 1992)

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Bluebook (online)
Joseph Leon Jenkins v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-leon-jenkins-v-state-texapp-2007.