84 N.Y.2d 477 (1994)
A defendant’s mere concurrence in a trial date set by the court, even if that date falls outside the 180-day speedy trial period mandated by the Interstate Agreement on Detainers (IAD), does not constitute a waiver of their speedy trial rights under the IAD.
Summary
Defendant Reid, incarcerated in Ohio, requested a speedy trial on pending New York charges under the Interstate Agreement on Detainers (IAD). At a hearing to set a trial date, defense counsel agreed to a date suggested by the court that was beyond the IAD’s 180-day speedy trial window. Reid later moved to dismiss the indictment, arguing a violation of his IAD speedy trial rights. The trial court denied the motion, holding Reid had waived his rights. The New York Court of Appeals reversed, holding that the burden to comply with the IAD falls on the prosecution and the courts, not the defendant, and mere concurrence in a trial date is not a waiver.
Facts
In December 1993, Monroe County officials lodged a detainer against Reid, who was imprisoned in Ohio, for murder and robbery charges. Reid invoked his rights under Article III of the IAD, requesting a final disposition of the New York charges. The request was received by the Monroe County Court and prosecutor on January 10, 1994, triggering the IAD’s 180-day speedy trial provision.
Procedural History
Reid was indicted on March 11, 1994. In May 1994, Reid filed pretrial motions, which the court decided in December 1994. On January 9, 1995, a trial date of May 1, 1995, was set with the defense’s agreement. On April 17, 1995, Reid moved to dismiss the indictment for failure to bring him to trial within the IAD’s 180-day period. The trial court denied the motion, and Reid was convicted. The Appellate Division affirmed. The New York Court of Appeals reversed, granting Reid’s motion to dismiss.
Issue(s)
Whether a defendant, by concurring in a trial date set by the court that falls outside the 180-day period mandated by the Interstate Agreement on Detainers (IAD), waives their right to a speedy trial under that statute.
Holding
No, because the burden of complying with the IAD’s speedy trial requirements falls on the prosecution and the courts, not the defendant, and mere concurrence in a trial date does not constitute an affirmative request for a trial date beyond the speedy trial period.
Court’s Reasoning
The Court of Appeals emphasized that the IAD’s purpose is to ensure the orderly and expeditious disposition of untried charges against prisoners incarcerated in other states. The Court noted that the IAD places the burden of compliance with its speedy trial provisions on the prosecution and the courts, not on the defendant. The Court distinguished between a defendant’s passive agreement to a trial date and an affirmative request for a delay. “From the statutory language and objectives it follows that the IAD does not impose an obligation on defendants to alert the prosecution or the court to their IAD speedy trial rights or to object to treatment that is inconsistent with those rights.” The Court cited Brown v. Wolff, 706 F.2d 902, 907 (9th Cir.), in support of this proposition. The Court reasoned that imposing such an obligation would shift the burden of compliance from state officials, diminishing the statute’s effectiveness. The Court stated, “Similarly, where, as here, the defendant simply concurred in a trial date proposed by the court and accepted by the prosecution, and that date fell outside the 180-day statutory period, no waiver of his speedy trial rights was effected.” Because Reid was not brought to trial within the 180-day period, the Court held that the indictment must be dismissed as mandated by IAD Article V(c).