People v. Ramlall

Decided:  February 13, 2020

Issue Presented: (1) Does the constitutional right to a speedy trial apply to traffic infractions? (2) Is a 971-day delay in a DWAI (driving while ability impaired) prosecution violate constitutional speedy trial principles?

Holding: (1) For now. (2) “Close” but no cigar.        

CAL Observes: 

The Court’s summary decision in Ramlall was a complete dodge on multiple fronts. The Court acknowledged that the enormous delay on the defendant’s DWAI traffic infraction charge—which survived long after two related misdemeanor charges had been dismissed on CPL 30.30 grounds and required the defendant to appear in court 29 times—presented a “close” case for a constitutional speedy trial violation. It would have been nice to know what, in the Court’s view, made the case “close” at all, and not a slam dunk speedy trial violation—especially so since this issue is almost certain to soon arise again. 

Separately, the Court could have expressly rejected the prosecution’s claim that traffic infractions are not entitled to constitutional speedy trial protections. Instead, the Court found that the prosecution failed to preserve the issue. Perhaps it’s a good thing that this issue was not reached by this generally defense-unfriendly Court.