City of Helena v. Heppner
Annotate this CaseDefendant was arrested for driving under the influence (DUI). Defendant was arraigned on May 23, 2012, and trial was set for August 27, 2012. Defendant’s trial, however, was postponed upon his motion to vacate the initial trial date for a change of plea. On October 1, 2012, the municipal court rearraigned Defendant, and he pled not guilty to the DUI. Defendant subsequently moved to dismiss on the grounds that his right to a speedy trial had been violated. The municipal court summarily denied Defendant’s motion without conducting any analysis. Defendant moved for reconsideration of his motion to dismiss under both the misdemeanor speedy trial statute and constitutional speedy-trial provisions. On May 9, 2013, Defendant pled guilty to DUI. The district court denied Defendant’s appeal. The Supreme Court reversed, holding (1) Defendant’s statutory speedy-trial right was not violated because his motion to vacate his trial date for a change of plea made the misdemeanor speedy-trial statute inapplicable; but (2) in regards to Defendant's constitutional speedy-trial violation claim, the delay in Defendant’s case was sufficient to trigger analysis under the factors set forth in State v. Ariegwe. Remanded.
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