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Ratliff v. State

Court of Appeals of Indiana

September 4, 2019

Jaron Leekingdus Ratliff, Appellant-Defendant,
v.
State of Indiana, Appellee-Plaintiff

          Appeal from the Delaware Circuit Court Trial Court Cause No. 18C01-1404-FA-1 The Honorable Marianne L. Vorhees, Judge

          Attorney for Appellant Samuel J. Beasley Muncie, Indiana

          Attorneys for Appellee Curtis T. Hill, Jr. Attorney General of Indiana Ian McLean Deputy Attorney General Indianapolis, Indiana

          May, Judge.

         [¶1] Jaron Leekingdus Ratliff appeals the trial court's denial of his motion to discharge the charges against him based on an alleged Criminal Rule 4(C) violation. Ratliff also argues the State violated his Sixth Amendment right to a speedy trial under the United States Constitution because there was a delay in bringing him to trial of over three years while he was incarcerated in another jurisdiction. We affirm.

         Facts and Procedural History

         [¶2] On April 1, 2014, police arrested Ratliff after he sold cocaine to two confidential informants. On April 8, 2014, the State charged Ratliff with two counts of Class A felony dealing in cocaine.[1] The trial court held an initial hearing on the matter on April 22, 2014, and set a trial date of August 11, 2014. On April 24, 2014, Ratliff was released on bail.

         [¶3] The trial court held a pre-trial hearing on May 3, 2014, and all parties attended. On July 7, 2014, the trial court held another pre-trial hearing, but Ratliff and his counsel did not appear. The trial court issued a warrant for Ratliff's arrest. On the scheduled trial date, Ratliff and his counsel again did not appear, but an unidentified third party announced on the Record that Ratliff was in the Madison County Jail and "he's going to be there for a while." (Tr. Vol. II at 4.) The trial court canceled the jury trial.

         [¶4] On March 29, 2018, the trial court scheduled a status conference on Ratliff's case for May 9, 2018. On May 9, Ratliff moved to continue the status conference, and the trial court rescheduled the status conference for June 13, 2018. On June 13, the trial court held the status conference. The next day, the court set a pretrial conference for July 25 and set Ratliff's jury trial for August 6, 2018.

         [¶5] On July 23, 2018, Ratliff filed a motion for discharge pursuant to Indiana Criminal Rule 4(C). On August 6, the trial court held a hearing on the matter and denied Ratliff's motion. The trial court then certified its order for interlocutory review, and we subsequently accepted jurisdiction.

         Discussion and Decision

         Discharge Under Indiana Criminal Rule 4(C)

         [¶6] Ratliff contends the trial court erred when it denied his motion for discharge pursuant to Indiana Criminal Rule 4(C). When we review Criminal Rule 4 claims, we review questions of law de novo and we review the trial court's factual findings under the clearly erroneous standard. Mefford v. State, 51 N.E.3d 327, 333 (Ind.Ct.App. 2016). Indiana Criminal Rule 4(C) provides:

No person shall be held on recognizance or otherwise to answer a criminal charge for a period in aggregate embracing more than one year from the date the criminal charge against such defendant is filed, or from the date of his arrest on such charge, whichever is later; except where a continuance was had on his motion, or the delay was caused by his act, or where there was not sufficient time to try him during such period because of congestion of the court calendar; provided, however, that in the last-mentioned circumstance, the prosecuting attorney shall file a timely motion for continuance as under subdivision (A) of this rule. Provided further, that a trial court may take note of congestion or an emergency without the necessity of a motion, and upon so finding may order a continuance. Any continuance granted ...

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