Paulo Ross was arrested in 2004 for a 2002 murder, released on bond, and indicted in 2011. He moved to dismiss the indictment for violating his constitutional right to a speedy trial, but the trial court initially denied the motion after a Barker v. Wingo analysis. After Ross’s first appeal was dismissed, the trial court reconsidered the ruling and granted a plea in bar, finding that the passage of time had degraded the evidence. The Georgia Supreme Court reversed. It explained that a trial court ordinarily loses authority to revoke an interlocutory ruling after the term in which it was entered, but may reconsider certain constitutional rulings when the evidentiary posture has materially changed. The passage of time and specific new deterioration in evidence can qualify, but the record here showed no material change between the two hearings. The State had already produced its discovery, Ross introduced no additional evidence, and his counsel acknowledged that he was relying on the earlier record. Eight of the eleven intervening months were also consumed by Ross’s abandoned appeal. Because the exception did not apply, the trial court lacked authority to reconsider its denial and grant the plea in bar. The Court reversed without deciding the underlying speedy-trial claim.