State v. Rogelio Trigo Jr.

CourtCourt of Appeals of Texas
DecidedJuly 5, 2012
Docket13-11-00474-CR
StatusPublished

This text of State v. Rogelio Trigo Jr. (State v. Rogelio Trigo Jr.) 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
State v. Rogelio Trigo Jr., (Tex. Ct. App. 2012).

Opinion

NUMBER 13-11-00474-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG

THE STATE OF TEXAS, Appellant,

v.

ROGELIO TRIGO JR., Appellee.

On appeal from the 36th District Court of San Patricio County, Texas.

MEMORANDUM OPINION Before Justices Rodriguez, Garza, and Vela Memorandum Opinion by Justice Vela This is a State's appeal from a motion to dismiss granted in favor of Rogelio Trigo

Jr. ("Trigo"). By one issue, the State contends that the trial court erred in granting the

motion to dismiss because Trigo failed to assert his speedy trial right. We affirm.

I. BACKGROUND

Trigo was arrested on October 15, 2009 in San Patricio County for felony drug

possession, and posted bond on November 16, 2009. See TEX. HEALTH & SAFETY CODE ANN. § 481.121 (West 2010). He attempted to file a motion for speedy trial in October

2010 with the San Patricio County District Clerk, but was unable to do so because there

was "no case" to file it in. Instead, Trigo filed his motion with the Justice of the Peace on

October 14, 2010. There is no record of an order on this motion. The State indicted

Trigo on May 10, 2011, approximately nineteen months after his arrest. Trigo filed a

post-indictment motion to dismiss on the ground that his right to speedy trial was violated.

The motion was granted by the trial court on June 17, 2011. The State subsequently

filed this appeal. See TEX. CODE CRIM. PROC. ANN. art. 44.01(a)(1) (West 2007).

II. STANDARD OF REVIEW

We apply a bifurcated standard when reviewing the trial court's ruling on a

speedy-trial motion: "an abuse-of-discretion standard for factual components, and a de

novo standard for legal components." Cantu v. State, 253 S.W.3d 273, 282 (Tex. Crim.

App. 2008). We view all of the evidence in the light most favorable to the trial court's

ruling. Id. A bifurcated standard of review is also applied when considering a trial

court's decision to dismiss the case. See State v. Krizan-Wilson, 354 S.W.3d 808, 815

(Tex. Crim. App. 2011). We give almost total deference to a trial court's findings of fact

that are supported by the record. Id.

III. APPLICABLE LAW

The right to a speedy trial is guaranteed independently by both the United States

Constitution and the Texas Constitution. See U.S. CONST. amend. VI; TEX. CONST. art. 1,

§ 10. The United States Supreme Court, in Barker v. Wingo, 407 U.S. 514, 530–31

(1972), established a framework for analyzing speedy trial claims. The Barker

framework requires consideration of: (1) the length of the delay; (2) the reasons for the

2 delay; (3) the assertion of the right; and (4) the prejudice to the defendant. Id. Texas

state courts analyze claims of a denial of the state speedy-trial right under the same four

Barker factors as federal courts. Cantu, 253 S.W.3d at 280. No single factor is

necessary or sufficient to establish a violation of the right to a speedy trial. Barker, 407

U.S. at 530, 533. Instead, we weigh the strength of each of the Barker factors and then

engage in a balancing test in light of "the conduct of both the prosecution and the

defendant." See Cantu, 253 S.W.3d at 281; Barker, 407 U.S. at 533. The State has the

burden of justifying the length of the delay, and the accused must prove the assertion of

the right to a speedy trial and prejudice. See Cantu, 253 S.W.3d at 280. The accused's

burden of proof "varies inversely" with the State's degree of culpability for the delay:

"The greater the State's bad faith or official negligence and the longer its actions delay a

trial, the less (an accused) must show actual prejudice or prove diligence in asserting [the]

right to a speedy trial." Id. at 280–81. After finding that an accused's right to a speedy

trial was actually violated, the charging instrument must be dismissed with prejudice.

See Barker, 407 U.S. at 533.

IV. ANALYSIS

By its sole issue, the State argues that Trigo failed to assert his speedy trial right

because he did not seek relief prior to his indictment. We analyze the arguments in

accordance with the Supreme Court's Barker decision.

A. First Barker Factor: Length of the Delay

The length of the delay is a "triggering mechanism" for analysis of the other factors.

Id. at 530, 533. There is no set time element, although the court of criminal appeals has

held a four-month delay to be insufficient, while finding a seventeen-month delay

3 "presumptively prejudicial." Cantu, 253 S.W.3d at 281; see Phillips v. State, 650 S.W.2d

396, 399 (Tex. Crim. App. 1983); Pete v. State, 501 S.W.2d 683, 687 (Tex. Crim. App.

1973). In this case, Trigo was arrested on October 15, 2009. He was not indicted until

May 10, 2011. The period of approximately nineteen months delay in this case is

presumptively prejudicial under Cantu and therefore triggers the analysis of the remaining

Barker factors.

B. Second Barker Factor: Reason for the Delay

After the delay is determined to be presumptively prejudicial, the State must justify

the delay. Turner v. State, 545 S.W.2d 133, 137–38 (Tex. Crim. App. 1976). "The

crucial question in determining the legitimacy of governmental delay may be whether it

might reasonably have been avoided—whether it was unnecessary." Dickey v. Florida,

398 U.S. 30, 52 (1970). In determining the necessity for the delay, the court can

consider the "intrinsic importance" of the reason, as well as the length of the delay and its

potential for prejudice. Id. "For a trivial objective, almost any delay could be reasonably

avoided. Similarly, lengthy delay, even in the interest of realizing an important objective,

would be suspect." Id.

In this case, the State failed to present any evidence as to a justification for the

delay. Trigo's attorney indicated that he encountered personnel and agency problems

when he attempted to get the case "moving" and was told that the case would be sent to

the District Attorney's office a second time. A "deliberate attempt to delay the trial"

weighs heavily against the State, while a "more neutral reason such as negligence or

overcrowded courts" will be weighed less heavily. State v. Munoz, 991 S.W.2d 818, 821

(Tex. Crim. App. 1999). The State did not meet its burden of providing justification for

4 the delay. Moreover, considering Trigo's attorney's representations, it appears that, at

worst, the State deliberately attempted to delay the trial and, at best, that they negligently

failed to pursue this case. See Cantu 253, S.W.3d at 280–81. Accordingly, we

conclude this factor weighs against the State.

C. Third Barker Factor: Assertion of the Speedy-Trial Right

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Related

Dickey v. Florida
398 U.S. 30 (Supreme Court, 1970)
Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Dillingham v. United States
423 U.S. 64 (Supreme Court, 1975)
Phillips v. State
650 S.W.2d 396 (Court of Criminal Appeals of Texas, 1983)
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)
Cantu v. State
253 S.W.3d 273 (Court of Criminal Appeals of Texas, 2008)
Pete v. State
501 S.W.2d 683 (Court of Criminal Appeals of Texas, 1973)
Harris v. State
489 S.W.2d 303 (Court of Criminal Appeals of Texas, 1973)
Turner v. State
545 S.W.2d 133 (Court of Criminal Appeals of Texas, 1977)
Harris v. State
827 S.W.2d 949 (Court of Criminal Appeals of Texas, 1992)
Guzman v. State
955 S.W.2d 85 (Court of Criminal Appeals of Texas, 1997)
State of Texas v. Wilson, Carolyn Sue Krizan
354 S.W.3d 808 (Court of Criminal Appeals of Texas, 2011)

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