California, United States of America
The following excerpt is from People v. Burrise, F080818 (Cal. App. 2021):
As explained in People v. Hayton (1979) 95 Cal.App.3d 413, "[t]he essence of a defendant's speedy trial claim in the usual case is that the passage of time has frustrated his ability to establish his innocence. The resolution of a speedy trial or due process issue necessitates a careful assessment of the particular facts of a case in order that the question of prejudice may be determined. [] Where the defendant pleads guilty, there are no facts to be assessed. And since a plea of guilty admits every element of the offense charged, there is no innocence to be established." (Id. at p. 419, fn. omitted.)
Similarly, in People v. Egbert, the court explained "the weighing process required to establish a constitutional speedy trial violation necessitates consideration of prejudice to the accused in the particular context of the case. By pleading guilty, a defendant concedes the absence of prejudice, having admitted '"all matters essential to the conviction."' [Citations.] Viewed in this way, a guilty plea in both felony and misdemeanor prosecutions forecloses any further inquiry into whether there has been a deprivation of a defendant's speedy trial right." (People v. Egbert, supra, 59 Cal.App.4th at p. 511, fn. omitted.)
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