What is the test for determining whether a delay in completing a criminal case was unreasonable?

California, United States of America


The following excerpt is from Shleffar v. Superior Court, 178 Cal.App.3d 937, 223 Cal.Rptr. 907 (Cal. App. 1986):

"It is perhaps an unfortunate, but nonetheless existing, fact of life in a democratic society that only so much time, manpower and money can be expended toward any single criminal case. Thus, we agree with the previously quoted principle [from Jones v. Superior Court (1970) 3 Cal.3d 734, 738, 91 Cal.Rptr. 578, 478 P.2d 10] that only in the case of 'willful oppression' or 'neglect' is the delay unreasonable. [Defendant] does not suggest that the delay was willful; and we hold that under the facts and circumstances here the delay was not unreasonable."

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