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Rivers v. State

Citations: 777 N.E.2d 51; 2002 Ind. App. LEXIS 1713; 2002 WL 31372157Docket: No. 49A02-0202-CR-116

Court: Indiana Court of Appeals; October 22, 2002; Indiana; State Appellate Court

Narrative Opinion Summary

The case involves the appeal of William 0. Rivers, who was convicted of robbery as a Class A felony after a bench trial. Rivers appealed on two grounds: the violation of his right to a speedy trial under Indiana Criminal Rule 4(C) and the Sixth Amendment, and the insufficiency of evidence supporting his conviction. The charges stemmed from a 1998 incident where Rivers and an accomplice planned to rob the home of Roberta Higginson, leading to her death from injuries sustained during the robbery. Rivers was charged on multiple counts including murder and robbery, and ultimately convicted of robbery following a trial on stipulated evidence. On appeal, the court affirmed his conviction, finding that Rivers waived his right to a speedy trial by failing to object to delays and requesting continuances. Applying the *Barker v. Wingo* analysis, the court found no violation of his constitutional right to a speedy trial, as the delays were primarily due to Rivers’ actions, including plea negotiations and an interlocutory appeal. The court also determined there was sufficient evidence to support his robbery conviction, as Rivers actively participated in the crime. The decision to affirm his conviction was unanimous among the judges.

Legal Issues Addressed

Constitutional Right to Speedy Trial

Application: The court applied the *Barker v. Wingo* factors and concluded that Rivers' constitutional right to a speedy trial was not violated due to his own actions causing the majority of the delay.

Reasoning: Rivers failed to demonstrate any prejudice resulting from the delay, as attempts to negotiate a plea—though unsuccessful—were part of the reason for the delay, and changes in counsel also contributed to the timeline.

Indiana Criminal Rule 4(C) and Right to Speedy Trial

Application: The court found that Rivers waived his right to a speedy trial under Indiana Criminal Rule 4(C) because he did not object to a trial date set beyond the one-year limit and requested continuances.

Reasoning: Rivers did not object to a trial date set outside the one-year period, thus waiving his right. Rivers had requested his trial to occur after a co-defendant's trial, leading to an indefinite continuance without a scheduled trial date.

Sufficiency of Evidence for Robbery Conviction

Application: The court upheld Rivers' robbery conviction, finding sufficient evidence of his active participation in the crime, including retrieving a gun and witnessing the assault.

Reasoning: The court concludes that Rivers' involvement and actions during the crime demonstrate sufficient evidence to uphold his robbery conviction.