Betterman v. Montana - 136 S. Ct. 1609 (2016)

Rule:

The course of a criminal prosecution is composed of discrete segments. During the segment between accusation and conviction, the Sixth Amendment’s Speedy Trial Clause protects the presumptively innocent from long enduring unresolved criminal charges. The Sixth Amendment speedy trial right, however, does not extend beyond conviction, which terminates the presumption of innocence.

Facts:

Petitioner Brandon Betterman pleaded guilty to bail jumping after failing to appear in court on domestic assault charges. He was then jailed for over 14 months awaiting sentence, in large part due to institutional delay. He was eventually sentenced to seven years' imprisonment, with four of the years suspended. Arguing that the 14-month gap between conviction and sentencing violated his speedy trial right, Betterman appealed, but the Montana Supreme Court affirmed the conviction and sentence, ruling that the Sixth Amendment’s Speedy Trial Clause did not apply to postconviction, presentencing delay.

Issue:

Did the Sixth Amendment Speedy Trial Clause apply to a delay between defendant’s conviction and sentencing? 

Answer:

No.

Conclusion:

The Court affirmed the judgment of the state supreme court, holding that the speedy trial guarantee protected an accused from arrest or indictment through trial, but did not apply once a defendant has been found guilty at trial or has pleaded guilty to criminal charges. According to the Court, the Speedy Trial Clause implemented the presumption of innocence, and therefore would lose force upon conviction. For inordinate delay in sentencing, although the Speedy Trial Clause did not govern, a defendant may have other recourse, including, in appropriate circumstances, tailored relief under the Due Process Clauses of the Fifth and Fourteenth Amendments. Petitioner, however, only advanced a Sixth Amendment speedy trial claim; thus, he did not preserve a due process challenge.