People v. Reginald Wiggins
Issue Before the Court: “[H]ow long is too long” for a defendant to wait for trial?
Held: The Court considered Mr. Wiggins’s constitutional speedy trial claim, finding that the prosecution may not seek to delay a trial indefinitely so that they might pursue evidence that could strengthen their case, even assuming a good-faith belief that the evidence would be useful. In this case, over six years at Rikers was too long.
CAL Observes: The Court was undoubtedly motivated by how extreme the delay was here, not to mention a number of fairly unique factors, such as Mr. Wiggins’s age (16 at the time of the incident and arrest); and the two-and-one-half years the prosecution spent trying to get a co-defendant to cooperate against him in this homicide case, which included the declaration of three mistrials in the co-defendant’s case. It also could not likely have been oblivious to the context in which the case was occurring—one of much-criticized delays in the New York City courthouses, the conditions at Rikers Island, especially for young people, and a growing chorus of voices for bail reform to avoid precisely the sort of prejudice and delays that occurred here—as the amici here pointed out.
Nonetheless, the case is in many ways a straightforward application of the Taranovich factors, balancing the various considerations to arrive at its conclusion (though the dissent would reach a different outcome, notwithstanding its acknowledgment that the delay was extraordinary and Mr. Wiggins’s incarceration at age 16 resulted in serious prejudice, as it would weigh the gravity of the offense heavily and believed there was a disputed question as to whether the defense “acquiesce[d] in the delay”). That said, a few things are of note. First, the Court finds that the People did not establish that Mr. Wiggins would be held on unrelated charges alone—arising out of a “jailhouse altercation”—if he were not facing the instant charges. Second, the Court reaffirms long-standing state and federal law that defendants need not show specific prejudice as opposed to just the inherent generalized prejudice that inheres when someone is incarcerated and there is a long delay.
Also of note to Court of Appeals practice is that the Court disregarded the People’s calls for it to treat the reason-for-delay question as a mixed one of law and fact. Instead, it determined that this was a question of whether their proffered reason was a sufficient one as a matter of law.