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“In addressing the alleged denial of the Sixth- Amendment right to a speedy trial, the court must typically consider: 1) the length of the delay; 2) the reason for the delay; 3) whether the defendant has demanded a speedy trial; and 4) the prejudice to the defendant.” (citing Barker, 407 U.S. at 530-32).

–69 (1984); ¶ 16 (App. 2007) (“A defendant who fails to establish that his 12 STATE v. WHITESIDE Decision of the Court defense was prejudiced or that he was deprived of a fair t

(denying relief to defendant who was “the cause for the delay about which she complains on appeal”); ¶ 15 (2012) (“[A] self-represented defendant must not only respect the dignity of the courtroom, but also comply with relevant rules.”) (cleaned up).

(A person’s absence may constitute an extraordinary circumstance under Rule 8 justifying a continuance.); ¶ 11 (App. 1998) (A continuance may not be warranted when a key witness’s scheduling conflict can be foreseen and avoided.); (A

¶17 In contrast, neither the Arizona Constitution nor the United States Constitution impose a specific time limit, Spreitz, 190 Ariz. at 139 (citations omitted), and courts instead examine “(1) the length of the delay; (2) the reason for the delay; (3) whether the defendant has demanded a speedy trial; and (4) the prejudice to the defendant,” (citing Barker v. Wingo, 407 U.S. 514, 530 (1972)).

(finding no reversible error when “defendant ha[d] not established that the technical speedy trial error in this case prejudiced his defense in any way or deprived him of a fair trial.”); (“There was no apparent impairment of appellee’s ability to defend herself, because there is no allegation of lost witnesses or evidence.”).

absent a clear abuse of the trial court’s discretion.’” ¶ 7 (App. 2005) (alteration in Snyder) ().

When analyzing a potential constitutional speedy trial violation, courts consider “1) the length of the delay; 2) the reason for the delay; 3) whether the defendant has demanded a speedy trial; and 4) the prejudice to the defendant.” (citing Barker v. Wingo, 407 U.S. 514 (1972)).

Courts use the four-part Barker test to determine whether speedy trial rights have been denied: “1) the length of the delay; 2) the reason for the delay; 3) whether the defendant has demanded a speedy trial; and 4) the prejudice to the defendant.” (citing Barker v. Wingo, 407 U.S. 514, 530 (1972)).

Similarly, our supreme court has emphasized — in a different context but quite relevant here — that “[a] prosecutor’s office cannot get around Brady by keeping itself in ignorance or compartmentalizing information about different aspects of a case.” , (quoting Carey v. Duckworth, 738 F.2d 875, 878 (7th Cir.1984)).

When it is alleged that the superior court improperly granted a Rule 8 continuance “[w]e will not disturb a ruling on a motion for continuance absent a clear abuse of the trial court’s discretion.”

(stating that illness of trial judge justified exclusion of reasonable time from speedy trial period where accused asserted no demonstrable prejudice).

Rule 15.7 provides that, for violations of the discovery rules, “the court may impose any sanction which it finds just under the circumstances.” Reviewing the trial court’s decision on sanctions for discovery violations for an abuse of discretion, , , we conclude that the trial court acted within its discretion by not precluding the state’s three witnesses from testifying.

339 , 88 L.Ed.2d 324 (1985); , see also Rule 15.7(a) (court may impose any sanction it finds just under the circumstances).

See , (illness or incapacity of trial judge justified exclusion of reasonable time from speedy trial period where accused asserts no demonstrable prejudice); Carter v. State, 54 Md.App.

(upholding imposition of continuance as appropriate sanction for discovery violations).