State v. Hall
In State v. Hall, 17 Conn. App. 502, 507, 554 A.2d 746 (1989), rev'd on other grounds, 213 Conn. 579, 569 A.2d 534 (1990), the Court rejected a defendant's claim that the trial court improperly denied his motion to dismiss a murder charge.
The defendant claimed that the three and one-half year delay between when the warrant for his arrest was issued and his subsequent arrest violated his sixth amendment right to a speedy trial, arguing that his right to a speedy trial "arose as of the date the arrest warrant issued . . . ." Id., 505.
In rejecting the defendant's sixth amendment claim, the Court stated:
"The issuance of an arrest warrant in and of itself does not trigger the sixth amendment right to a speedy trial of a person not yet arrested. . . . Absent a formal charge, the sixth amendment right to a speedy trial does not extend to the period prior to the arrest." Id., 507.
Because the defendant argued a delay relating to a period before he was arrested or formally charged by information or indictment, we held that the sixth amendment was not implicated. See id.