Watson v. State

• Decision Date: 21 October 2020
• Docket Number: Supreme Court Case No. 20S-CR-64
• Parties: Stanley V. WATSON, Appellant (Defendant) v. STATE of Indiana, Appellee (Plaintiff)
• Court: Indiana Supreme Court

155 N.E.3d 608

Stanley V. WATSON, Appellant (Defendant)

v.STATE of Indiana, Appellee (Plaintiff)

Supreme Court Case No. 20S-CR-64

Supreme Court of Indiana.

Argued: May 27, 2020

Filed October 21, 2020

ATTORNEY FOR APPELLANT: Cara S. Wieneke, Wieneke Law Office, LLC, Brooklyn, Indiana

ATTORNEYS FOR APPELLEE: Curtis T. Hill, Jr., Attorney General of Indiana, Stephen R. Creason, Chief Counsel, Samuel J. Dayton, Deputy Attorney General, Indianapolis, Indiana

On Petition to Transfer from the Indiana Court of Appeals, No. 19A-CR-49

Rush, Chief Justice.

The right to a speedy trial—one of our oldest guarantees—imposes an affirmative duty on the government to ensure that criminal defendants receive the swift administration of justice. This fundamental right is safeguarded by the Sixth Amendment to the United States Constitution; Article 1, Section 12 of our Indiana Constitution; and Indiana Criminal Rule 4.

Here, Stanley Watson was serving an eighty-year sentence—including fifty years for a single drug conviction—when the trial court vacated his thirty-year habitual-offender enhancement. The State was granted permission to retry the habitual-offender allegation, but it would be over six years before that happened. During those years of waiting, Watson repeatedly communicated his desire to be tried; and he eventually filed a motion to dismiss, asserting violations of Criminal Rule 4(C) and his constitutional right to a speedy trial. The trial court denied the motion, however, and Watson was found to be a habitual offender.

We reverse. Although Criminal Rule 4(C) does not apply to a habitual-offender retrial, Watson's constitutional right to a speedy trial was violated by the extraordinary six-plus-year delay. We thus remand with instructions to vacate Watson's habitual-offender enhancement.

Facts and Procedural History

In 2001, a jury convicted Stanley Watson of felony dealing in cocaine and found he was a habitual offender. The trial court subsequently sentenced Watson to eighty years in prison—fifty years for the drug conviction and thirty years for the habitual-offender enhancement.

Two years later, Watson challenged the enhancement in a petition for post-conviction relief. Eventually—in April 2012—the State conceded that two of the convictions supporting the habitual-offender finding were insufficient. So, the court granted relief and vacated the thirty-year enhancement. But then, in July of that year, the State was granted permission to retry Watson on the habitual-offender allegation.

It would be 2,325 days—nearly six and a half years—before he was retried.¹ The table below shows the intervening events that occurred while Watson, from his prison cell, awaited resolution of the outstanding charge.

2013
January 14	Watson moves to continue the January 29 trial—reset for September.
September 16	Watson moves to continue the trial—reset for June 2014.
November 14	The court, on its own motion, continues the trial to July 2014.
2014
June 16	Watson moves to continue the trial—reset for February 2015.
2015
January 21	The judge recuses himself, and Watson's February trial date is removed from the calendar.
January 28	A special judge is appointed.
August 12	The judge accepts the appointment.
September 29	Watson, in a letter to the court, asks for an update and requests a new trial date.
October 20	The court sets the trial for April 2016.
December 9	Watson, in a letter to the court, writes, "I want to get this trial over."

2016
March 9	The State, over Watson's objection, moves to continue the trial—reset for October.
May 10	The court, on its own motion, moves the trial date up from October 18 to October 4.
October 3	The State, over Watson's objection, moves to continue the trial—reset for March 2017.
2017
March 21	Watson's trial date comes and goes—nothing happens.
April 11	Watson, in a letter to the court, expresses confusion over why his March trial didn't take place. He assumes "it was continued again" and asks for the new trial date.
October 5	The State files a motion to set a trial date, and the special judge recuses himself.
October 11–12	A second special judge is appointed, but that judge also recuses himself. A third special judge is appointed.
November 20	The court sets trial for May 2018.
2018
April 13	Watson's attorney withdraws representation. The court appoints new counsel.
April 30	Watson's new attorney moves to continue the trial—reset for November.
November 15	Watson files a motion to dismiss, alleging a violation of Indiana Criminal Rule 4(C) and his constitutional right to a speedy trial.
November 27	Watson's trial takes place, and the jury finds that he is a habitual offender.

The day after Watson's trial, the court denied his motion to dismiss. It found that Indiana Criminal Rule 4(C) "does not apply to retrials after vacation or reversal of a conviction" and that Watson's constitutional right to a speedy trial was not violated. Watson appealed, arguing that the six-plus-year delay violated Rule 4(C) and his constitutional rights to both a speedy trial and due process.

In a split decision, the Court of Appeals reversed and vacated Watson's habitual-offender enhancement, concluding that he should have been discharged under Criminal Rule 4(C). Watson v. State , 135 N.E.3d 982, 987–88 (Ind. Ct. App. 2019). Judge Kirsch dissented, believing that relief under Rule 4(C) did not apply to Watson's claim. Id. at 988 (Kirsch, J., dissenting).

We granted transfer, vacating the Court of Appeals opinion. Ind. Appellate Rule 58(A).

Standard of Review

Watson contends that the trial court improperly denied his motion to dismiss. In evaluating Watson's speedy trial claims, we review factual findings for clear error and questions of law de novo. Austin v. State , 997 N.E.2d 1027, 1040 & n.10 (Ind. 2013) ; State v. Azania , 865 N.E.2d 994, 1002 (Ind. 2007), clarified on reh'g on other grounds , 875 N.E.2d 701.

Discussion and Decision

The right to a speedy trial is one of this country's most basic, fundamental guarantees—one much older than the nation itself. Klopfer v. North Carolina , 386 U.S. 213, 223–24, 87 S.Ct. 988, 18 L.Ed.2d 1 (1967) (citing Magna Carta, c. 29 (1225), reprinted in Edward Coke, The Second Part of the Institutes of the Laws of England 45 (Brooke, 5th ed., 1797)). It protects against "prolonged detention without trial" as well as unreasonable "delay in trial." Id. at 224, 87 S.Ct. 988.

To safeguard these protections, the State and the courts—together, the government—have an obligation to ensure the timely prosecution of criminal defendants. See, e.g. , Logan v. State , 16 N.E.3d 953, 964–65 (Ind. 2014) ; Fisher v. State , 933 N.E.2d 526, 530 (Ind. Ct. App. 2010). At times, however, that obligation may remain unfulfilled. When that happens, a defendant can draw on three sources to assert a violation of this fundamental right.

The first two are found in the Sixth Amendment to the United States Constitution and Article 1, Section 12 of the Indiana Constitution. When evaluating whether a defendant's constitutional speedy trial right has been infringed, we use the balancing test announced by the Supreme Court of the United States in Barker v. Wingo , 407 U.S. 514, 92 S.Ct. 2182, 33 L.Ed.2d 101 (1972). See, e.g. , Logan , 16 N.E.3d at 961. The test assesses both the government's and the defendant's conduct and takes into consideration (1) the length of the delay, (2) the reason for the delay, (3) the defendant's assertion of the speedy trial right, and (4) any resulting prejudice. Barker , 407 U.S. at 530, 92 S.Ct. 2182. Though this analysis is grounded in the Sixth Amendment, we have traditionally also applied it to claims brought under Article 1, Section 12. See, e.g. , Crawford v. State , 669 N.E.2d 141, 145 (Ind. 1996) (citing Fortson v. State , 269 Ind. 161, 169, 379 N.E.2d 147, 152 (1978) ).²

A third source of protection is Indiana Criminal Rule 4, which gives defendants another path to ensure the speedy administration of justice. See Curtis v. State , 948 N.E.2d 1143, 1147 n.3 (Ind. 2011). This rule establishes time limits for prosecution and provides for discharge of a defendant when those limits are exceeded. Bridwell v. State , 659 N.E.2d 552, 553 (Ind. 1995). More specifically, Criminal Rule 4(C) —the relevant subsection here—places an affirmative duty on the State to bring a defendant to trial within one year from the later of two dates: (1) the filing of charges or (2) the arrest. Ind. Crim. R. 4(C). Importantly, Criminal Rule 4 does not cover every aspect of its broader constitutional counterparts. Cundiff v. State , 967 N.E.2d 1026, 1027 n.2 (Ind. 2012). And thus, our review of a Rule 4 challenge is separate from a claimed constitutional violation. Logan , 16 N.E.3d at 958.

Here, Watson waited nearly six and a half years before he was retried on the State's habitual-offender allegation. He contends that this delay violates his right to a speedy trial under Criminal Rule 4(C) and the state and federal constitutions. The State responds that Watson is not entitled to relief, arguing that Rule 4(C) does not apply to retrials and that the delay was not unconstitutional.

Both parties are partially correct. While Criminal Rule 4(C) does not apply to habitual-offender retrials, the six-plus-year delay violated Watson's constitutional right to a speedy trial.³

I. Criminal Rule 4(C) does not apply to the retrial of a habitual-offender allegation.

Criminal Rule 4(C) requires the State to bring a defendant to trial within one year, excluding delays caused by the defendant or court congestion. The one-year clock is triggered by the later of either the date charges are filed or the date of the defendant's arrest. Because these occur at the beginning stages of a criminal prosecution, we have previously held that Rule 4(C) —by its language—does not anticipate mistrials or retrials. See James v. State , 716 N.E.2d 935, 939 (Ind. 1999) ; State ex rel. Brumfield v. Perry Cir. Ct. , 426 N.E.2d 692, 695 (Ind. 1981). Watson acknowledges this general principle, but he argues...