State of Iowa v. Deyawna Leanett Taylor

Summary

The Supreme Court of Iowa held that the State failed to establish either good cause for delaying trial beyond Iowa's ninety-day speedy-trial deadline or a knowing and intelligent waiver by the defendant. The court rejected reliance on Taylor's incarceration in another county, her proffer agreement, and the timing of her pretrial motion to dismiss. It vacated the court of appeals decision, reversed the district court judgment, and remanded for dismissal of all charges.

Holdings

1. The State failed to establish good cause for the delay because it presented no evidence showing due diligence in locating Taylor or bringing her to court while she was in state custody.
2. The State failed to prove that Taylor knowingly and intelligently waived her speedy-trial right through the proffer agreement; mere acquiescence to a delayed trial is insufficient.
3. Taylor did not waive speedy trial solely by filing her pretrial motion to dismiss two days before the scheduled trial.

Questions Presented

1. Whether the State established good cause for failing to bring Taylor to trial within ninety days under Iowa Rule of Criminal Procedure 2.33(2)(b).
2. Whether Taylor knowingly and intelligently waived her speedy-trial right by entering into the proffer agreement after the speedy-trial deadline had expired.
3. Whether Taylor waived her speedy-trial right by asserting it only two days before the scheduled trial.

Disposition

reversed_and_remanded