REDDING v. STATE
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In this case, the Supreme Court of Georgia was asked to review the conviction of Merrick Redding, who was found guilty of felony murder and aggravated assault in connection with the death of Joseph Davis. Redding appealed his conviction several times, arguing that his Sixth Amendment right to a speedy trial was violated. The Court had previously vacated the judgment and remanded the case back to the trial court for fact-finding and legal conclusions on the speedy trial issue. On remand, the trial court again denied Redding's speedy trial motion, leading to the current appeal.
The Supreme Court of Georgia examined the trial court’s application of the four-factor test from Barker v. Wingo and Doggett v. United States to evaluate Redding's constitutional speedy trial claim. The factors are: the length of the delay, the reasons for the delay, the defendant's assertion of his right to a speedy trial, and prejudice to the defendant.
In its analysis, the Court found that the trial court erred in weighing the length of delay and the reasons for delay as neutral. It should have weighed these factors against the State since the delay was uncommonly long and solely attributable to the State. The Court found no abuse of discretion in the trial court's decision to weigh neutrally the defendant's assertion of his right to a speedy trial and to weigh the prejudice factor heavily against Redding.
Because the trial court misapplied the law and made factual errors, the Supreme Court of Georgia vacated the trial court's order denying Redding’s speedy-trial motion and again remanded the case for the trial court to resolve the speedy-trial claim. The Court noted that the trial court may still have discretion to deny Redding’s motion after properly weighing the factors. It did not address any other claims of error raised by Redding.
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