Flores-Gomez v. State
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The Supreme Court affirmed Defendant's conviction of first-degree sexual abuse of a minor, holding that Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48.
Defendant was charged with one count of first-degree sexual abuse of a minor. On April 9, 2018, the district court arraigned Defendant, starting the 180-day speedy trial clock. Defendant's trial, however, was not held within 180 days of his arraignment. Instead, Defendant's trial commenced on October 15, 2018, 190 days later. At issue was whether the district court properly continued the trial beyond the 180-day mandate of Rule 48(b). The Supreme Court affirmed, holding (1) the district court properly granted a continuance under Wyo. R. Crim. P. 48(b)(4)(A) even though Defendant did not agree to a continuance and the motion was not supported by a written affidavit; and (2) therefore, the ten-day continuance did not count toward the 180-day limit, and Defendant was not denied his right to a speedy trial.
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