which includes the reasons for the delay.” See also Spicer, 222 Or App at 222 (making the same observation). Our assertion in Davids that delays of 15 months or more are generally unreasonable should be understood in context with Harman and our explanation in Forsyth and Spicer. 8 The additional 3.5-month delay may have been attributable to the defendant. We remanded to the trial court to determine which party actually bore responsibility, stating that, if it was attributable to the defendant, the pertinent delay would be less than one year and would not be unreasonable under the circumstances. Allen, 205 Or App at 228-29. 9 The point at which that occurs varies depending on the strength of the reasons for the delay. To put it bluntly, some reasons ar 42, rev den, 336 Or 125 (2003)
holding that a delay of more than four years caused largely by the state making pretrial appeals was reasonable under the circumstances holding only two months of four year and eight month delay attributable to commonwealth where defendant fled and concealed his whereabouts for four years and six months holding the delays of more than six years did not amount to the denial of access to the courts holding that a delay of more than eight years attributable to the normal workings of the appellate process in addressing a pretrial appeal is reasonable recognizing the prejudice of an extension to a defendant who would be required to litigate events that occurred more than eight years earlier