Appeals Court Vacates Ruling in Murder Case Over Speedy Trial Violations

The Georgia Court of Appeals has vacated a lower court’s ruling that denied Quillian Donta Nelson’s motion to dismiss his murder indictment on constitutional speedy trial grounds. Nelson is charged in connection with the June 3, 2020, fatal shooting of Darwin Davis.
Nelson was arrested on June 5, 2020, and asserted his right to a speedy trial on August 7, 2020. However, he was not indicted until more than a year later, on August 23, 2021. His motion to dismiss the indictment was denied by the trial court on September 11, 2024.
The appellate court found multiple errors in the trial court’s ruling, including misapplication of the Barker v. Wingo and Doggett v. United States frameworks for evaluating speedy trial claims. Specifically:
- The trial court failed to properly analyze the length of delay, merely noting it was “presumptively prejudicial” without assigning it weight or addressing whether it was unusually long.
- The court incorrectly blamed the defense for delays in trial, citing leaves of absence that were not shown to have caused postponements.
- The court misstated the timeline of when Nelson asserted his right to a speedy trial, claiming it was three years after his arrest when records show it was two months after his arrest and before his indictment.
- The court failed to evaluate Nelson’s testimony on the prejudice he suffered—including claims of being stabbed in jail, anxiety, and lack of medical treatment—due to an erroneous interpretation of legal precedent.
The appellate court concluded that the lower court’s ruling was based on factual and legal errors and remanded the case for further consideration under the correct standards.