Rush, CJ.
The right to a speedy trial—one of our oldest guarantees—imposes an affirmative duty on the government to ensure that criminal defendants receive the swift administration of justice. This fundamental right is safeguarded by the Sixth Amendment to the United States Constitution; Article 1, Section 12 of our Indiana Constitution; and Indiana Criminal Rule 4. Here, Stanley Watson was serving an eighty-year sentence—including fifty years for a single drug conviction—when the trial court vacated his thirty-year habitual-offender enhancement. The State was granted permission to retry the habitual-offender allegation, but it would be over six years before that happened. During those years of waiting, Watson repeatedly communicated his desire to be tried; and he eventually filed a motion to dismiss, asserting violations of Criminal Rule 4(C) and his constitutional right to a speedy trial. The trial court denied the motion, however, and Watson was found to be a habitual offender. We reverse. Although Criminal Rule 4(C) does not apply to a habitual-offender retrial, Watson’s constitutional right to a speedy trial was violated by the extraordinary six-plus-year delay. We thus remand with instructions to vacate Watson’s habitual-offender enhancement.
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The right to a speedy trial is one of this country’s most basic, fundamental guarantees—one much older than the nation itself. Klopfer v. North Carolina, 386 U.S. 213, 223–24 (1967) (citing Magna Carta, c. 29 (1225), reprinted in Edward Coke, The Second Part of the Institutes of the Laws of England 45 (Brooke, 5th ed., 1797)). It protects against “prolonged detention without trial” as well as unreasonable “delay in trial.” Id. at 224. To safeguard these protections, the State and the courts—together, the government—have an obligation to ensure the timely prosecution of criminal defendants. See, e.g., Logan v. State, 16 N.E.3d 953, 964–65 (Ind. 2014); Fisher v. State, 933 N.E.2d 526, 530 (Ind. Ct. App. 2010). At times, however, that obligation may remain unfulfilled. When that happens, a defendant can draw on three sources to assert a violation of this fundamental right.
The first two are found in the Sixth Amendment to the United States Constitution and Article 1, Section 12 of the Indiana Constitution. When evaluating whether a defendant’s constitutional speedy trial right has been infringed, we use the balancing test announced by the Supreme Court of the United States in Barker v. Wingo, 407 U.S. 514 (1972). See, e.g., Logan, 16 N.E.3d at 961. The test assesses both the government’s and the defendant’s conduct and takes into consideration (1) the length of the delay, (2) the reason for the delay, (3) the defendant’s assertion of the speedy trial right, and (4) any resulting prejudice. Barker, 407 U.S. at 530. Though this analysis is grounded in the Sixth Amendment, we have traditionally also applied it to claims brought under Article 1, Section 12.
A third source of protection is Indiana Criminal Rule 4, which gives defendants another path to ensure the speedy administration of justice. See Curtis v. State, 948 N.E.2d 1143, 1147 n.3 (Ind. 2011). This rule establishes time limits for prosecution and provides for discharge of a defendant when those limits are exceeded. Bridwell v. State, 659 N.E.2d 552, 553 (Ind. 1995). More specifically, Criminal Rule 4(C)—the relevant subsection here—places an affirmative duty on the State to bring a defendant to trial within one year from the later of two dates: (1) the filing of charges or (2) the arrest. Ind. Crim. R. 4(C). Importantly, Criminal Rule 4 does not cover every aspect of its broader constitutional counterparts. Cundiff v. State, 967 N.E.2d 1026, 1027 n.2 (Ind. 2012). And thus, our review of a Rule 4 challenge is separate from a claimed constitutional violation. Logan, 16 N.E.3d at 958.
Here, Watson waited nearly six and a half years before he was retried on the State’s habitual-offender allegation. He contends that this delay violates his right to a speedy trial under Criminal Rule 4(C) and the state and federal constitutions. The State responds that Watson is not entitled to relief, arguing that Rule 4(C) does not apply to retrials and that the delay was not unconstitutional. Both parties are partially correct. While Criminal Rule 4(C) does not apply to habitual-offender retrials, the six-plus-year delay violated Watson’s constitutional right to a speedy trial.
…[W]e reinforce here that Criminal Rule 4(C)’s triggering mechanism forecloses its application to the retrial of a habitual-offender allegation, see Brumfield, 426 N.E.2d at 695. Thus, Watson is not entitled to relief under Rule 4(C). But this does not end our inquiry—we now turn to whether he was denied his constitutional right to a speedy trial.
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Pursuant to a defendant’s constitutional right to a speedy trial— secured by the Sixth Amendment to the United States Constitution and Article 1, Section 12 of the Indiana Constitution—both the State and courts have an obligation to ensure the speedy administration of justice. This constitutional guarantee primarily protects three interests of criminal defendants: (1) preventing oppressive pretrial incarceration; (2) minimizing anxiety and concern; and (3) limiting the possibility that the defense will be impaired. Barker, 407 U.S. at 532. To safeguard those interests, we apply the Barker balancing test. Sweeney v. State, 704 N.E.2d 86, 102–03 (Ind. 1998).
The Barker test weighs the conduct of the government against the conduct of the defendant. 407 U.S. at 530. This requires an examination of four nonexclusive factors: (1) was the delay uncommonly long; (2) who is more responsible for the delay; (3) did the defendant assert their right to a speedy trial; and (4) did the defendant suffer prejudice because of the delay. Doggett v. United States, 505 U.S. 647, 651 (1992) (citing Barker, 407 U.S. at 530). No individual factor is “a necessary or sufficient condition” for a speedy trial violation; instead, each inquiry is related and must be considered together in the context of a particular case. Barker, 407 U.S. at 533. This analysis provides a framework by which courts can preserve the integrity of this constitutional right—one that has been described as “slippery” and “amorphous.” See id. at 522.
With this framework in hand, we will now determine whether Watson was denied his constitutional right to a speedy trial.
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All four Barker factors weigh in Watson’s favor. First, six-plus years of delay to try Watson on a habitual-offender allegation is uncommonly long. Second, the government is responsible for a majority of that delay. Third, Watson appropriately asserted his right to a speedy trial. And finally, Watson has shown prejudice resulting from the extraordinary delay. And so, we find that Watson was denied his constitutional right to a speedy trial.
Watson is not entitled to discharge under Criminal Rule 4(C) because that rule does not apply to the retrial of a habitual-offender allegation. But an analysis of the relevant factors reveals that Watson’s constitutional right to a speedy trial was violated, and thus, he is entitled to relief. We reverse the trial court and remand with instructions to vacate Watson’s habitual-offender enhancement.
David, Massa, and Goff, JJ., concur.
Slaughter, J., concurs, except as to Part II.C.