Doggett v. United States
505 U.S. 647 (1992)
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Rule of Law:
An extraordinary delay between indictment and trial, caused by government negligence, can violate a defendant's Sixth Amendment speedy trial right even without a specific showing of prejudice. The presumption of prejudice strengthens over time and may be sufficient on its own when the government is at fault for a long, unjustified delay.
Facts:
- In February 1980, a federal grand jury indicted Marc Doggett for conspiracy to import and distribute cocaine.
- In March 1980, police went to arrest Doggett at his parents' home, but his mother informed them he had left for Colombia four days earlier.
- The Drug Enforcement Administration (DEA) entered an arrest warrant for Doggett into a nationwide crime database, but an entry in a customs database expired later that year and was not renewed.
- In September 1981, the DEA learned Doggett was arrested in Panama on drug charges, but after Panamanian authorities released him in July 1982, he traveled to Colombia and then re-entered the U.S. unhindered.
- From late 1982 until 1988, Doggett lived openly in Virginia under his own name, married, earned a college degree, and held a steady job.
- The DEA agent in charge of the case learned in 1985 that Doggett had left Panama years earlier but made no further effort to locate him, assuming he was in Colombia.
- In September 1988, the U.S. Marshal's Service ran a simple credit check on old warrants and located Doggett within minutes.
- Doggett was arrested 8.5 years after his indictment, having been unaware of the charges against him during the intervening period.
Procedural Posture:
- Doggett filed a motion to dismiss the indictment in U.S. District Court, claiming a violation of his Sixth Amendment right to a speedy trial.
- A Federal Magistrate recommended denying the motion, finding that although the delay was long and due to government negligence, Doggett had failed to show any specific prejudice.
- The District Court adopted the Magistrate's recommendation and denied the motion to dismiss.
- Doggett entered a conditional guilty plea, reserving his right to appeal the speedy trial issue.
- Doggett, as appellant, appealed to the U.S. Court of Appeals for the Eleventh Circuit, with the United States as appellee.
- A divided panel of the Court of Appeals affirmed the conviction, holding that Doggett's claim failed without a showing of actual prejudice.
- The U.S. Supreme Court granted Doggett's petition for a writ of certiorari.
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Issue:
Does an 8.5-year delay between indictment and arrest, attributable to government negligence, violate the Sixth Amendment right to a speedy trial even if the defendant cannot show specific prejudice to his defense?
Opinions:
Majority - Justice Souter
Yes. An 8.5-year delay between indictment and arrest, attributable to government negligence, violates the Sixth Amendment right to a speedy trial even if the defendant cannot show specific prejudice to his defense. The Court applied the four-factor balancing test from Barker v. Wingo: (1) length of delay, (2) reason for the delay, (3) the defendant’s assertion of his right, and (4) prejudice to the defendant. The 8.5-year delay was extraordinary and presumptively prejudicial. The reason for the delay was the government's negligence, as it made no serious effort to find Doggett for six years despite his living openly in the U.S. Doggett cannot be faulted for not asserting his right, as he was unaware of the indictment. Critically, while Doggett did not show particularized prejudice, excessive delay presumptively compromises the reliability of a trial. The presumption of prejudice intensifies as the delay lengthens, and when it is caused by government negligence of this duration, it is sufficient to warrant relief without an affirmative showing of specific harm.
Dissenting - Justice O'Connor
No. A defendant must show actual prejudice to their defense before a court weighs potential harm in the speedy trial balance. The mere possibility or speculation of prejudice is insufficient to establish a violation of the Sixth Amendment. Delay is a 'two-edged sword' that can also impair the government's ability to prove its case. The Court of Appeals correctly required Doggett to prove actual prejudice, which he failed to do.
Dissenting - Justice Thomas
No. The Speedy Trial Clause is designed to protect against two core evils: oppressive pretrial incarceration and the anxiety of a public accusation, neither of which Doggett experienced because he was at liberty and unaware of the indictment. Impairment of a defense due to the passage of time is not an independent interest protected by the Speedy Trial Clause; it is protected by statutes of limitations and the Due Process Clause. Because Doggett suffered no deprivation of liberty that the Clause protects, the Barker v. Wingo balancing test should not even apply. The majority's holding improperly transforms the judiciary into a supervisory body for law enforcement efficiency rather than a protector of individual rights that have actually been harmed.
Analysis:
This decision significantly clarifies the prejudice prong of the Barker v. Wingo speedy trial test. It establishes that in cases of extraordinary and unjustified delay caused by government negligence, prejudice to the defense can be presumed without a specific showing of harm, such as a lost witness. This holding creates a sliding scale where the government's culpability for a protracted delay lessens the defendant's burden to demonstrate actual prejudice. It serves as a strong incentive for the government to diligently pursue prosecutions, as its own lethargy can trigger a Sixth Amendment violation, even where the defendant's defense is not demonstrably impaired.
