Doggett v. United States, 505 U.S. 647 (1992), is a Supreme Court case addressing the right to a speedy trial under the Sixth Amendment.
Facts:
Marc Doggett was indicted in 1980 for drug-related charges. Shortly after the indictment, he left the United States. While authorities knew he was in Colombia and later Panama, they failed to apprehend him due to logistical issues. In 1982, Doggett returned to the U.S. unnoticed and lived openly for the next six years. He was arrested in 1988, but during this time, he had no knowledge of the indictment.
Issue:
Does an 8½-year delay between the indictment and arrest, largely due to government negligence, violate the defendant’s Sixth Amendment right to a speedy trial?
Holding:
Yes, the Supreme Court ruled in favor of Doggett, holding that the delay violated his right to a speedy trial.
Reasoning:
The Court applied the Barker v. Wingo (1972) balancing test, which considers:
Length of delay: The 8½-year delay was presumptively prejudicial.
Reason for delay: The government was negligent in pursuing Doggett, as they could have located him with reasonable effort.
Defendant’s assertion of the right: Doggett could not assert his right earlier because he was unaware of the indictment.
Prejudice to the defendant: The Court presumed prejudice due to the excessive delay caused by government negligence, even without specific proof of harm to Doggett’s defense.
Outcome:
The Court reversed Doggett’s conviction, emphasizing that a lengthy, negligent delay by the government undermines the defendant’s Sixth Amendment right, even if the defendant cannot show concrete prejudice.
This case underscores the importance of timely prosecution and holds the government accountable for unnecessary delays in pursuing charges.
Anton Vialtsin, Esq.
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