Can Court Impose a Prison Sentence After Sentencing Has Been Postponed Indefinitely ?
In Miller v. Aderhold, 288 U.S. 206 (1933), the defendant pleaded guilty to stealing from the United States mails, and the trial court postponed sentencing indefinitely and released the defendant.
Six months later, a different trial judge sentenced the defendant to four years' imprisonment.
The Court concluded that the six-month delay did not deprive the trial court of jurisdiction to sentence the defendant.
The Court noted that because the order postponing sentencing was void, the defendant could have eliminated any prejudice from the brief delay by requesting a sentencing hearing.
Because the defendant failed to make such a request, he consented to the delay. Miller, 288 U.S. at 210.
However, the Court did not consider whether a longer delay could deny a defendant his due process rights. In Miller, the defendant expected a brief delay and was sentenced six months after he was convicted.