Doggett v. United States

Brief Fact Summary. Government prosecutes petitioner Marc Gilbert Doggett on drug charges eight and one half years after he was indicted.

Synopsis of Rule of Law. Unreasonable delay between indictment and prosecution violates a criminal defendant’s Sixth Amendment right to a speedy trial.

Facts. Petitioner was indicted in February of 1980 for conspiracy to import and distribute cocaine, and when government agents went to his house to arrest him they found out he was in Colombia. Nineteen months later they found out he was in Panama. One year later he passed through customs without being stopped and settled in Virginia. Six years later the government found out he was there by running a credit check, and he was arrested and prosecuted. He filed a motion to dismiss, claiming that his right to a speedy trial was violated by the government’s failing to prosecute him earlier, and his motion was denied. The Court of Appeals affirmed and he was granted certiorari.

Issue. Does an eight and one half year delay between indictment and prosecution violate a criminal defendant’s right to a speedy trial?

Held. Yes. Reverse and remand.
Reverse the conviction because the eight and one half year delay was sufficient to trigger the speedy trial inquiry. Also, the Federal Government offered nothing to show that they were not negligent in seeking the individual.

The fact that the petitioner did not invoke his right to a speedy trial earlier is not fatal because no evidence was shown that he was aware of his indictment prior to the arrest.

Petitioner not showing trial prejudice does not mean that relief cannot be granted.

Dissent. Justice Sandra Day O’Connor dissented by saying that the possibility of prejudice does not mean that speedy trial rights have been violated.
Justice Clarence Thomas dissented by saying that the Sixth Amendment’s speedy trial guarantee was designed to prevent oppressive incarceration and the anxiety accompanying public accusation, and neither was implicated here. Also, independent protection against prejudice to an accused’s defense or the disruption of the accused’s life are not protected by the Sixth Amendment.

Discussion. Practically, it is unclear how beneficial this decision is considering that the delay in time was so long under these facts. The case does mention that lower courts usually find a one year post-accusation delay as presumptively prejudicial, but does not really lay out a more specific standard than to say that “unreasonable” delay is what is not allowed.