State v. Washington

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The speedy indictment rule commences upon arrest only when the arrest is completed by making an initial appearance. Therefore, the speedy indictment rule does not require the dismissal of a trial information against a defendant filed more than forty-five days after the defendant was taken into custody, interrogated, and released without the filing of a criminal complaint. This case arose out of the same facts and presented the same issues address in a companion case also decided today, State v. Williams, __ N.W.2d __ (Iowa 2017). The district court concluded that Defendant’s speedy indictment rights had not been violated. The court of appeals reversed. Based on the reasoning in Williams, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "State v. Washington" on Justia Law