Watson v. State
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The Supreme Court reversed the order of the trial court denying Defendant's motion to dismiss his habitual offender enhancement, holding that Defendant's constitutional right to a speedy trial was violated by an extraordinary six-plus-year delay.
Defendant was serving an eighty-year sentence when the trial court vacated his thirty-year habitual offender enhancement. The court granted the State permission to retry the habitual offender allegation, but it would be nearly six and a half years before Defendant was retried. Before his retrial, Defendant filed a motion to dismiss, alleging a violation of Ind. Crim. R. 4(C) and his constitutional right to a speedy trial. The court denied Defendant's motion to dismiss. After a trial, a jury found that Defendant was a habitual offender. The Supreme Court reversed, holding (1) Defendant was not entitled to discharge under Rule 4(C) because that rule does not apply to the retrial of a habitual offender allegation; but (2) Defendant's constitutional right to a speedy trial was violated, and therefore, Defendant was entitled to relief.
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