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.
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.
Consideration of prejudice is not limited to the specifically demonstrable, and, affirmative proof of particularized prejudice is not essential to every speedy trial claim.View Full Point of Law
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.