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Law School Case Brief

Doggett v. United States - 505 U.S. 647, 112 S. Ct. 2686 (1992)

Rule:

To trigger a speedy trial analysis, an accused must allege that the interval between accusation and trial has crossed the threshold dividing ordinary from "presumptively prejudicial" delay. If the accused makes this showing, the court must then consider, as one factor among several, the extent to which the delay stretches beyond the bare minimum needed to trigger judicial examination of the claim.

Facts:

In February 1980, petitioner Doggett was indicted on federal drug charges, but he left the country before the Drug Enforcement Agency (DEA) could secure his arrest. The DEA knew that he was later imprisoned in Panama, but after requesting that he be expelled back to the United States, never followed up on his status. Once the DEA discovered that he had left Panama for Colombia, it made no further attempt to locate him. Thus, it was unaware that petitioner re-entered the U.S. in 1982 and subsequently married, earned a college degree, found steady employment, lived openly under his own name, and stayed within the law. The Marshal's Service eventually located him during a simple credit check on individuals with outstanding warrants. He was arrested in September 1988, 8 1/2 years after his indictment. He moved to dismiss the indictment on the ground that the Government's failure to prosecute him earlier violated his Sixth Amendment right to a speedy trial, but the District Court denied the motion, and he entered a conditional guilty plea. The Court of Appeals affirmed the district court’s decision. Thereafter, petitioner challenged the decision.

Issue:

Was the petitioner’s Sixth Amendment right to a speedy trial violated by the Government’s failure to prosecute him earlier, despite the fact that he was living openly under his own name?

Answer:

Yes.

Conclusion:

The United States Supreme Court held that the delay between petitioner’s indictment and arrest violated his Sixth Amendment right to a speedy trial. According to the Court, petitioner’s claim met the Barker v. Wingo criteria for evaluating speedy trial claims. First, the extraordinary 8 1/2-year lag between his indictment and arrest clearly sufficed to trigger the speedy trial inquiry. Second, the Government was to blame for the delay. The District Court's finding that the Government was negligent in pursuing petitioner should be viewed with considerable deference, and neither the Government nor the record provided any reason to reject that finding. Third, petitioner asserted in due course his right to a speedy trial. The courts below found that he did not know of his indictment before his arrest, and, in the factual basis supporting his guilty plea, the Government essentially conceded this point. Finally, the negligent delay between petitioner’s indictment and arrest presumptively prejudiced his ability to prepare an adequate defense. The Court averred that under the circumstances, it was reversible error for the Court of Appeals to hold that the individual’s speedy trial claim had to fail due to the individual’s failure to show actual prejudice, as the Government’s egregious persistence in failing to prosecute the individual was sufficient to warrant relief even without a showing of particularized trial prejudice.

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