State v. Watson
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The Supreme Court reversed the ruling of the district court denying Defendant's motion to dismiss the trial information filed against her, holding that the State violated the speedy indictment rule.
On July 5, 2020, Defendant was issued citations in lieu of arrest for several misdemeanors. Defendant's initial appearance happened on September 21, and the State filed its trial information on October 6. Defendant subsequently filed her motion to dismiss, arguing that a citation in lieu of arrest triggers the speedy indictment rule, and the State failed timely to file the trial information within forty-five days of the citations issued against her or even within a sixty-day extended deadline under the Supreme Court's supervisory order. The district court denied the motion to dismiss. The Supreme Court reversed, holding (1) the district court should have counted the forty-five days from the date the citations issued rather than Defendant's initial appearance; (2) the district court erred by ruling that the COVID-19 pandemic provided good cause for the delay in indicting Defendant; and (3) Defendant was entitled to dismissal under Iowa R. Crim. P. 2.33(2)(a).
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