Watson v. StateAnnotate this Case
The Supreme Court reversed the judgment of the trial court denying Defendant's motion to dismiss the State's habitual-offender allegation and remanded with instructions to vacate Defendant's habitual-offender enhancement, holding Defendant's constitutional right to a speedy trial was violated by a six-plus-year delay.
Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual-offender enhancement. More than six years passed before the State retried the habitual-offender allegation. Defendant filed a motion to dismiss, but the trial court denied the motion, eventually finding Defendant to be a habitual offender. The Supreme Court reversed, holding (1) Criminal Rule 4(C) does not apply to a habitual-offender retrial; but (2) Defendant's right to a speedy trial was violated, and therefore, Defendant was entitled to relief.