State v. Krizan-Wilson
Carolyn Sue Krizan-Wilson was indicted for murder nearly 23 years after her husband's death. She moved to dismiss the indictment, arguing prosecutorial delay violated her rights to due process, speedy trial, due course of law, fair trial, testify, present a defense, and effective representation, and that the indictment was barred by laches. The trial court granted the motion, dismissing the indictment. The State of Texas appealed this decision. The appellate court analyzed the due process claim under a two-prong test requiring both substantial prejudice and intentional delay for tactical advantage or bad faith. While acknowledging Krizan-Wilson suffered substantial prejudice due to the delay, including loss of witnesses, evidence, and her mental deterioration, the court found no evidence that the delay was intentional or for improper purposes. Consequently, the appellate court reversed the trial court's order of dismissal, finding no merit in any of the grounds cited for dismissal and remanding the case for further proceedings.