## Facts

- Rockey Moore was charged with murder in Arizona while incarcerated in California.
- Arizona lodged a detainer against Moore but did not promptly bring him to trial.
- Nearly three years passed between the charge and Moore’s eventual trial in Arizona.
- During the delay, Moore repeatedly demanded that Arizona extradite him for trial or remove the detainer.
- Before trial, Moore sought state habeas relief, alleging a violation of his Sixth and Fourteenth Amendment right to a speedy trial.

## Issues

1. Whether a defendant must affirmatively show prejudice to the defense at trial as a necessary condition to establish a federal constitutional speedy-trial violation.
2. Whether the state court applied the correct constitutional standard for evaluating a speedy-trial claim involving an incarcerated defendant subject to an out-of-state detainer.

## Decision

- The Supreme Court granted certiorari, vacated the Arizona Supreme Court’s judgment, and remanded.
- The Court held the Arizona Supreme Court committed fundamental error by treating prejudice to the trial defense as an essential prerequisite to a speedy-trial claim.
- The Court directed reconsideration under the Barker v. Wingo multi-factor balancing approach, including scrutiny of the reasons for delay and the State’s diligence in seeking trial of an incarcerated defendant.

## Legal Principles

- Speedy-trial claims are evaluated by balancing factors identified in Barker v. Wingo: length of delay, reason for delay, defendant’s assertion of the right, and prejudice to the defendant.
- No single Barker factor is necessary or sufficient; courts must consider them together in a sensitive, circumstance-specific balance.
- Prejudice from delay is not limited to impairment of the defense at trial; it includes restraints on liberty, anxiety, disruption of life, and for incarcerated defendants, potential effects on parole and rehabilitation.
- When a defendant is imprisoned in another jurisdiction and demands trial, the prosecuting state must make a diligent, good-faith effort to bring the defendant to trial and courts must weigh the reasons for any delay.

## Conclusion

The Court ruled that Arizona used an improper speedy-trial standard by requiring affirmative proof of trial-defense prejudice and remanded for application of the Barker balancing test, including the State’s responsibility to pursue trial diligently despite the defendant’s incarceration elsewhere.


Moore v. Arizona, 414 U.S. 25 (1973)