People v. Taranovich, 37 N.Y.2d 442 (1975)
A determination of whether a defendant’s Sixth Amendment right to a speedy trial has been violated requires a balancing of the conduct of the prosecution and the defendant, with particular attention to events toward the end of the relevant time period.
Summary
The New York Court of Appeals affirmed the Appellate Division’s orders, holding that despite 22- and 29-month delays between arrest and trial, the defendant’s Sixth Amendment right to a speedy trial was not violated. The court emphasized that much of the delay was attributable to the defendant’s own actions, including his dissatisfaction with assigned counsel and defense-instigated delays on the eve of trial. Furthermore, the defendant did not object to earlier delays caused by the prosecution and court. The court applied a balancing test, weighing the conduct of both the prosecution and the defendant to determine if the delay prejudiced the defendant’s rights.
Facts
The defendant was subject to two indictments that experienced significant delays between arrest and trial: 22 months for one, and 29 months for the other. During the period leading up to the trial, the defendant expressed dissatisfaction with several assigned counsel, requiring their replacement. On the eve of trial, defense counsel indicated that the defendant was largely responsible for the delays.
Procedural History
The case originated with two indictments against the defendant. After delays in bringing the case to trial, the case reached the Appellate Division, whose orders were affirmed by the New York Court of Appeals.
Issue(s)
Whether the delays of 22 and 29 months between the defendant’s arrest and trial constituted a violation of the defendant’s Sixth Amendment right to a speedy trial, thereby warranting dismissal of the indictments.
Holding
No, because the delays were significantly attributable to the defendant’s actions, and the defendant failed to object to earlier delays caused by the prosecution and the court. The totality of the circumstances did not demonstrate a violation of the defendant’s Sixth Amendment rights.
Court’s Reasoning
The court reasoned that delay alone does not automatically constitute a violation of a defendant’s constitutional right to a speedy trial. Rather, a balancing test must be applied, weighing the conduct of both the prosecution and the defendant. Citing People v. Blakley, 34 N.Y.2d 311, the court emphasized that courts should especially review events occurring toward the end of the relevant time period. The Court also pointed to People v. Prosser, 309 N.Y. 353, 359, 360 to emphasize the importance of contemporaneous objections. In this case, the court found that significant delays were instigated by the defense, and earlier delays were either justified or not objected to by the defendant. As a result, the defendant had no grounds for complaint. The court stated, “Delay alone does not automatically breach the defendant’s constitutional and statutory rights. Each such case must be determined on balance, i.e., the conduct of the prosecution and that of the defendant are weighed.”