Doggett v. United States

In Doggett v. United States, 505 U.S. 647 (1992), the defendant was indicted on February 22, 1980, for conspiring to import and distribute cocaine. Shortly after being indicted, the defendant left the United States for Columbia. In September, 1982, the defendant returned to the United States and lived openly under his own name. The defendant was arrested on September 5, 1988, eight and one-half years after being indicted, after a marshal's service ran a routine credit check on individuals subject to outstanding arrest warrants. Doggett v. United States, supra, 505 U.S. 648-650. The defendant sought to dismiss the indictment, arguing that the eight and one-half year delay in prosecuting him violated his sixth amendment right to a speedy trial. The United States Supreme Court reversed the judgment of the District Court denying the defendant's motion. Relying on the four factors that it enunciated in Barker v. Wingo, 407 U.S. 514 (1972), the court found that the delay between the defendant's indictment and subsequent arrest violated his sixth amendment right to a speedy trial. Doggett v. United States, supra, 657-659. The Supreme Court observed that the lower courts have generally found post accusation delay to be presumptively prejudicial at least as it approaches one year. Id. at 652. The Court further advised that, in this threshold context, the term 'presumptive prejudice' simply marks the point at which courts deem the delay unreasonable enough to trigger the Barker inquiry. Id. In Doggett, the court found that a eight and a half year delay in arresting an accused from the date of his indictment violated his speedy trial rights as guaranteed by the Sixth Amendment. The court applied the Barker criteria and found that Doggett's failure to cite any specifically demonstrable prejudice did not doom his claim. Doggett, 505 U.S. at 658, 112 S. Ct. at 2694. The court held that the government's egregious persistence in failing to prosecute Doggett was sufficient to warrant granting relief. Id. The court found that the negligence caused a delay six times longer than generally deemed sufficient to trigger judicial review, and the presumption of prejudice was neither extenuated by Doggett's acquiescence, nor persuasively rebutted. Id. The United States Supreme Court observed: "On its face, the Speedy Trial Clause is written with such breadth that, taken literally, it would forbid the government to delay the trial of an 'accused' for any reason at all. Our cases, however, have qualified the literal sweep of the provision by specifically recognizing the relevance of four separate enquiries: whether delay before trial was uncommonly long, whether the government or the criminal defendant is more to blame for that delay, whether, in due course, the defendant asserted his right to a speedy trial, and whether he suffered prejudice as the delay's result." ( Id. at p. 651). The Court determined that the defendant would have faced trial six years earlier than he did, "but for the Government's inexcusable oversights," and held that, because "the Government's negligence thus caused delay six times as long as that generally sufficient to trigger judicial review, . . . and because the presumption of prejudice, albeit unspecified, was neither extenuated, as by the defendant's acquiescence, nor persuasively rebutted, the defendant was entitled to relief." 505 U.S. at 658.