the state here exceeded 15 months, a limit that we have treated as a rough outer boundary of reasonableness in misdemeanor cases. See State v. Davids, 193 Or App 178, 183, 90 P3d 1 (2004), aff’d, 339 Or 96, 116 P3d 894 (2005) (observing that “the courts generally have concluded that state-caused delays to which a defendant has not consented of 15 months or more are generally unreasonable”). In addition, unlike in Spicer, the unjustified delay here did not constitute the majority of the total period of delay attributable to the state. Moreover, this is 09, rev den, 348 Or 523 (2010) (17.5-month delay attributable to the state on misdemeanor offenses did not require dismissal where each portion of the delay was reasonable); State v. Cunningham, 232 Or App 135, 146-47, 221 P3d 165 (2009) (<HOLDING>). Under all the attendant circumstances in this
holding that teachers request for four months leave was not a reasonable accommodation holding that petitioners unexplained hence unjustified delay of at least six months was not reasonable for purposes of california law holding that dismissal was required where overall length of prosecution was 16 months state was responsible for 13 months of delay and six months of that delay was due to simple neglect holding that a 15month delay of which four months were unexplained was reasonable in a felony prosecution 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