Flowers v. Warden

How later courts describe this case

• applying "clearly erroneous" standard of review to trial court's finding that child sexual abuse victim's hearsay statements were "trustworthy" as required by V.R.E. 804a(a)(4)
• no sixth amendment violation even though only reason for 17-month delay, during which defendant was unable to post bail and remained incarcerated, was court docket congestion
• no violation of right to speedy trial despite seventeen-month incarceration caused by congested courts