The Sixth Amendment speedy-trial right begins with formal accusation or actual restraints from arrest and holding to answer, not the earlier investigative interval. Limitation statutes are the primary protection against stale charges, while due process can have a limited role upon proof of actual prejudice and improper delay.
Material limitation
Marion did not establish one complete abstract test for every due-process preaccusation-delay claim. Lovasco further explains the prejudice-and-reason inquiry.