Gary Durham was convicted of rape and child molestation after a delay of more than six years between his arrest and trial. He argued that the delay violated his constitutional right to a speedy trial and that the trial court should have granted his plea in bar. The trial court made oral findings under the four-factor test from Barker v Wingo, but it never entered a written order containing findings of fact and conclusions of law. The Georgia Court of Appeals vacated the judgment and remanded with direction. Under Georgia precedent, the appellate court must have a proper written order to review the trial court’s exercise of discretion on a constitutional speedy-trial claim. Oral comments made before trial were not enough, particularly because the Supreme Court of Georgia had required a remand for a proper order in a similar case. The appellate court did not reach Durham’s mistrial, sufficiency, or other claims because those issues depended on completion of the speedy-trial record.