State v. Griffin
848 S.W.2d 464, 1993 WL 45952, 1993 Mo. LEXIS 20 (1993)
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Rule of Law:
A pre-indictment delay violates a defendant's due process rights only if the defendant can prove two elements: (1) that the delay caused actual and substantial prejudice to their defense, and (2) that the prosecution intentionally delayed the indictment to gain a tactical advantage.
Facts:
- On July 12, 1983, Reginald Griffin and co-defendant Doyle Franks murdered fellow inmate James Bausley while all were incarcerated at the Moberly Training Center for Men.
- The investigation into Bausley's murder was completed by September 13, 1983.
- After the murder, prison officials placed Griffin in administrative segregation for disciplinary reasons.
- The local prosecutor, who was the sole attorney in his office, decided to try his capital cases in the order they arose and was also dealing with serious personal matters, including an accident involving his infant daughter.
- Due to the prosecutor's caseload and personal issues, he did not file a complaint against Griffin until January 28, 1987, more than three years after the investigation concluded.
Procedural Posture:
- Reginald Griffin was charged with capital murder in a Missouri circuit court (trial court).
- A jury found Griffin guilty of capital murder and he was sentenced to death by the trial court.
- Griffin filed a direct appeal of his conviction and sentence to the Supreme Court of Missouri.
- The direct appeal was suspended while Griffin pursued a post-conviction motion to vacate his conviction in the trial court, alleging ineffective assistance of counsel.
- The trial court held hearings and subsequently overruled the motion to vacate.
- Griffin appealed the denial of his post-conviction motion to the Supreme Court of Missouri.
- The Supreme Court of Missouri consolidated Griffin's direct appeal and his appeal from the denial of the post-conviction motion for its review.
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Issue:
Does a pre-indictment delay of over three years violate a defendant's due process rights when the delay was caused by the prosecutor's personal issues and caseload, and the defendant cannot show that the delay caused substantial prejudice to his defense?
Opinions:
Majority - Benton, Judge
No, the pre-indictment delay does not violate the defendant's due process rights. To require dismissal of charges for a pre-indictment delay, the court applies a two-prong test from State v. Scott, requiring the defendant to show both (1) actual prejudice from the delay and (2) that the prosecution intended the delay to gain a tactical advantage. Griffin failed to meet either prong. He did not demonstrate actual prejudice, as the testimony of deceased witnesses would have been merely cumulative or was contradicted by physical evidence, and fading memories affected witnesses for both sides equally. Furthermore, the reason for the delay—the prosecutor's heavy caseload and personal tragedies—was unfortunate but not a malicious attempt to gain a tactical advantage. The court also held that Griffin's Sixth Amendment right to a speedy trial was not implicated because that right does not attach until a person is formally accused, and administrative segregation by prison officials is not equivalent to a formal criminal accusation. The court affirmed Griffin's conviction but reversed his death sentence and remanded for a new punishment hearing due to a separate, critical error: the admission into evidence during the penalty phase of the criminal record of a different person also named Reginald Griffin, which the court deemed 'manifest injustice' and not harmless error.
Analysis:
This decision reinforces the high threshold required for a defendant to succeed on a due process claim based on pre-indictment delay. It clearly distinguishes between negligent or unavoidable delays caused by resource limitations or personal issues and deliberate, strategic delays intended to disadvantage the accused. By finding the prosecutor's reasons unfortunate but not tactical, the court limits the scope of such claims to cases involving demonstrable bad faith from the prosecution. The case also highlights the distinct analyses for due process delay claims (pre-charge) and Sixth Amendment speedy trial claims (post-charge), clarifying that internal prison discipline does not trigger the latter. Finally, the reversal of the sentence—despite upholding the conviction—underscores the heightened scrutiny courts apply to the penalty phase of capital cases, where prejudicial evidentiary errors are less likely to be considered harmless.
