While Coutta, 385 S.W.3d 641, made it pretty difficult to claim any harm from delay in disposition of an appeal, the court chose to examine whether an appellate delay constitutes a violation of due process using the four speedy trial factors of Barker v. Wingo. Maybe even that analysis is made inapplicable by the decision in Betterman v. Montana, which holds the speedy provision of the Sixth Amendment simply detaches upon conviction.

I have always opposed seemingly excessive delays in the appellate process, but there seems to be little that can be done to discourage them, although the Texas intermediate courts recently touted improvement in their efficiency.