What is the legal test for denying a defendant a right to speedy trial?

Whether the question is approached under due process principles or those relating to the denial of the right to speedy trial makes no difference. The question in each case is '. . . decided by the same approach, namely, balancing the effect of the delay on the defendant against any justification for the delay.' (Jones v. Superior Court (1970) 3 Cal.3d 734, 741, fn. 1, 91 Cal.Rptr. 578, 583, 478 P.2d 10, 15.)

It goes without saying that deliberate suppression of evidence by prosecuting authorities denies a defendant due process of law. (People v. Kiihoa (1960) 53 Cal.2d 748, 752, 3 Cal.Rptr. 1, 349 P.2d 673.) No evidence is presented in these cases that a defendant has been subjected to deliberate deception, or to the wilful suppression of evidence material to a defense.