State v. Coffin10/6/1999
ause if the juror's views would `prevent or substantially impair the performance of his [or her] duties as a juror in accordance with his [or her] instructions and his [or her] oath.'" State v. Sutphin, 107 N.M. 126, 129, 753 P.2d 1314, 1317 (1988) (quoting Wainwright v. Witt, 469 U.S. 412, 424 (1985) (quoting Adams v. Texas, 448 U.S. 38, 45 (1980))). Because a trial court's decision to excuse a prospective juror for cause based on his or her views on the death penalty will necessarily depend on "a Judge's determination of that juror's demeanor and credibility," id., "the trial court is in the best position to `assess a juror's state of mind.'" State v. Clark, 1999- NMSC-035, 5, ___ N.M. ___, ___ P.2d ___ (quoting Sutphin, 107 N.M. at 129, 753 P.2d at 1317). As a result, we review a trial court's excusal for cause of a prospective juror for "a clear abuse of discretion or manifest error." Sutphin, 107 N.M. at 130, 753 P.2d at 1318.
{53} The trial court in this case concluded that, despite some minor inconsistency, Ms. Bachicha's overall response clearly indicated that she could not give the death penalty under any circumstances. Based on our review of the record, we conclude that the trial court did not abuse its discretion. In any case, we reject Coffin's argument that the proper remedy for any error in this circumstance would be the reversal of his conviction. The improper excusal of a prospective juror for cause based on the juror's views on capital punishment requires that a death sentence be vacated. Gray v. Mississippi, 481 U.S. 648, 659-61 (1987). However, an excusal of this nature affects only the sentencing phase of a death penalty trial and does not affect the determination of guilt. See Bumper v. North Carolina, 391 U.S. 543, 545 (1968); see also Witherspoon v. Illinois, 391 U.S. 510, 517-18 (1968). Because Coffin did not receive the death penalty and has presented no evidence that the jury was unable to impartially determine his guilt or innocence, any potential error in excusing Ms. Bachicha for her inability to impose the death penalty could not have caused any prejudice to Coffin.
V. Right to a Speedy Trial
{54} The police arrested Coffin on March 11, 1995. Coffin's trial began on June 17, 1996. Coffin argues that this fifteen-month, six-day delay violated his right to a speedy trial under the Fourteenth Amendment to the United States Constitution.
{55} The Sixth Amendment to the United States Constitution provides that " n all criminal prosecutions, the accused shall enjoy a right to a speedy and public trial." This provision is applicable to the states through the Fourteenth Amendment. Klopfer v. North Carolina, 386 U.S. 213, 222-23 (1967). The United States Supreme Court has established a four-part test for evaluating potential violations of the constitutional right to a speedy trial: "Length of delay, the reason for the delay, the defendant's assertion of his [or her] right, and prejudice to the defendant." Barker v. Wingo, 407 U.S. 514, 530 (1972). The first part of this test, length of the delay, serves a dual function. Doggett v. United States, 505 U.S. 647, 651 (1992). As an initial matter, the length of the delay must "cross the threshold dividing ordinary from `presumptively prejudicial' delay" in order to trigger further inquiry. Id. at 651-52 (quoting Barker, 407 U.S. at 530). If further inquiry is warranted, the length of delay must then be balanced with the other three factors to determine whether there has been a violation of the Constitution. Id. at 652.
{56} This case involves a fifteen-month, six-day delay between the time of arrest and the time of trial. See United States v. Marion, 404 U.S. 307, 320 (1971)
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