Betterman v. Montana
578 U.S. 437, 136 S. Ct. 1609 (2016)
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Rule of Law:
The Sixth Amendment's Speedy Trial Clause does not apply to the post-conviction, pre-sentencing phase of a criminal prosecution. The right attaches at the time of arrest or formal charge and terminates upon conviction.
Facts:
- Brandon Betterman was charged with domestic assault in Montana.
- After failing to appear in court for the domestic assault charges, he was additionally charged with bail jumping.
- Betterman pleaded guilty to the bail-jumping charge.
- Following his guilty plea, Betterman was incarcerated for over 14 months while awaiting his sentence.
- The delay in sentencing was primarily attributable to institutional factors, including the time taken to complete a presentence report and the court's slowness in scheduling a sentencing hearing.
Procedural Posture:
- Brandon Betterman pleaded guilty to bail jumping in a Montana state trial court.
- While awaiting sentencing, Betterman moved to dismiss the charge, arguing the 14-month post-conviction delay violated his Sixth Amendment right to a speedy trial.
- The Montana trial court denied the motion and imposed a sentence.
- Betterman, as appellant, appealed to the Supreme Court of Montana, the state's highest court.
- The Montana Supreme Court affirmed the trial court's judgment, holding that the Speedy Trial Clause does not apply to post-conviction, pre-sentencing delays.
- The United States Supreme Court granted certiorari to resolve a conflict among lower courts on the issue.
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Issue:
Does the Sixth Amendment's speedy trial guarantee apply to the post-conviction, pre-sentencing phase of a criminal prosecution?
Opinions:
Majority - Justice Ginsburg
No. The Sixth Amendment's speedy trial guarantee does not apply once a defendant has been found guilty at trial or has pleaded guilty to criminal charges. The Court reasoned that the Speedy Trial Clause is designed to protect the interests of the presumptively innocent accused, such as preventing oppressive pretrial incarceration and minimizing the anxiety of public accusation. These protections lose their force upon conviction, which extinguishes the presumption of innocence. The Court's reading is consistent with the historical understanding of the terms 'accused' and 'trial' at the time of the founding. Furthermore, the sole remedy for a speedy trial violation is dismissal of the charges, which would be an unjustified windfall for a validly convicted defendant facing sentencing delay. While the Speedy Trial Clause does not govern this phase, defendants are not without recourse; they may find protection against exorbitant delays under statutory rules or the Due Process Clause.
Concurring - Justice Thomas
Agrees with the Court's holding but writes separately to emphasize that the Court has not decided what analytical framework should be used to evaluate a Due Process Clause challenge to sentencing delays. He cautions against assuming that the test from Barker v. Wingo would apply, suggesting that the availability of state remedies like a writ of mandamus could satisfy due process requirements. The issue should be left for a case where it is properly briefed and argued.
Concurring - Justice Sotomayor
Agrees with the Court's holding but writes to highlight that the question of the proper test for a Due Process challenge to sentencing delay remains open. She suggests that the flexible four-factor test from Barker v. Wingo, which is already used by a majority of federal circuits for this purpose, seems well-suited to capture the concerns in the sentencing delay context. She would consider adopting the Barker test in an appropriate future case.
Analysis:
This decision provides a clear demarcation for the temporal scope of the Sixth Amendment's speedy trial right, definitively ending its application at conviction. By foreclosing Sixth Amendment claims for sentencing delays, the Court shifts the legal battleground for such issues to the Due Process Clause. This requires future litigants to frame their arguments under a different, more flexible standard, likely focusing on fundamental fairness rather than the specific protections associated with the presumption of innocence. The ruling provides clarity for lower courts but may make it more difficult for defendants to challenge post-conviction delays successfully.
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