Summary
The Massachusetts Supreme Judicial Court considered whether prolonged delays in obtaining custody of two defendants from Federal prison authorities violated their constitutional rights to a speedy trial. Applying the Barker v. Wingo balancing test, the court held that the delay violated Nickoyan Wallace's rights but not Timi Wallace's, affirming the trial court's rulings on their motions to dismiss.
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Practice areas
Questions Presented
- Whether the delay of more than nine years between the issuance of the murder complaints and the defendants' Superior Court arraignments violated their rights to a speedy trial under the Sixth Amendment to the United States Constitution and article 11 of the Massachusetts Declaration of Rights.
- Whether the Commonwealth's delay in filing detainers under the Interstate Agreement on Detainers required dismissal under Mass. R. Crim. P. 36(d)(3).
Holdings
- Once the period between formal accusation and trial is presumptively prejudicial, the court must apply the four-factor Barker balancing test, weighing the length of delay, reasons for delay, the defendant's assertion of the right, and prejudice.
- Timi Wallace's right to a speedy trial was not violated.
- Nickoyan Wallace's right to a speedy trial was violated, requiring allowance of his motion to dismiss.
- Delay in filing a detainer under Mass. R. Crim. P. 36(d)(3) does not warrant dismissal absent a showing of actual prejudice; constitutional presumptive prejudice does not replace that requirement.
Factual background
Tasfa Wallace was shot and killed in March 2000, and witnesses identified his brothers, Timi and Nickoyan Wallace, near the scene. Criminal complaints issued the next day, but both brothers fled Massachusetts and were later prosecuted and imprisoned federally for an armed robbery committed in Rhode Island. Although Massachusetts prosecutors knew that the brothers were in federal custody, they did not file detainers under the Interstate Agreement on Detainers until July 2009, and the brothers were arraigned on the Massachusetts murder charges later that year.
Procedural history
Murder indictments were returned in the Superior Court in 2002. In 2010, the Superior Court judge denied Timi Wallace's motion to dismiss but allowed Nickoyan Wallace's motion, finding a speedy-trial violation as to Nickoyan. The Appeals Court affirmed the denial of Timi's motion and reversed the allowance of Nickoyan's motion. The Supreme Judicial Court granted further appellate review and affirmed the trial court's rulings.