Prenesti v. State
In Prenesti v. State, 594 P.2d 63 (Alaska 1979) the Alaska Supreme Court rejected a claim of pre-accusation delay.
The defendant in Prenesti asserted that he had been prejudiced by the State's delay in charging him "because ... he was unable to locate several possible eyewitnesses to the incident who might have exonerated him". Id., 594 P.2d at 64.
The supreme court responded: "We agree with the superior court that the loss of these witnesses was due to Prenesti's failure to exercise due diligence in his own behalf. He became aware that he was the subject of a police investigation two months after the incident, but did not hire a lawyer until three months after that time or an investigator until seven months had passed." Id. at 65.