Strunk v. United States
1973 U.S. LEXIS 54, 37 L. Ed. 2d 56, 412 U.S. 434 (1973)
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Rule of Law:
Once a judicial determination has been made that an accused has been denied their Sixth Amendment right to a speedy trial, the only constitutionally permissible remedy is to reverse the conviction, vacate the sentence, and dismiss the indictment.
Facts:
- Petitioner, Strunk, transported a stolen automobile from Wisconsin to Illinois, which led to a federal charge.
- Strunk was already serving a one-to-three-year sentence in the Nebraska State Penitentiary for a state conviction.
- While incarcerated in Nebraska, Strunk freely admitted his guilt to an FBI agent after receiving proper warnings and stated his intention to demand a speedy trial under Fed. Rule Crim. Proc. 20.
- The government subsequently postponed prosecution of the federal charge, asserting that Strunk’s reference to Rule 20 contributed to the delay and that a large portion of the 10-month delay was attributable to Strunk.
- The government also cited a lack of staff personnel and insufficient appropriations in the United States Attorney’s Office as justification for the delay.
- Strunk neither showed nor claimed that the preparation of his defense was prejudiced by the delay.
Procedural Posture:
- Strunk was found guilty in United States District Court of transporting a stolen automobile and sentenced to a five-year term, to run concurrently with an existing state sentence.
- Prior to trial, the District Court denied Strunk's motion to dismiss the federal charge, in which he argued he had been denied his right to a speedy trial.
- The Court of Appeals reversed the District Court, holding that Strunk had in fact been denied a speedy trial.
- However, the Court of Appeals went on to hold that dismissal of the charges was not warranted and remanded the case to the District Court to reduce Strunk's sentence by 259 days to compensate for the delay.
- The Supreme Court granted certiorari on Strunk's claim that, once a speedy trial denial is found, the only available remedy is dismissal of the indictment.
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Issue:
Does the Sixth Amendment's guarantee of a speedy trial require the dismissal of an indictment as the exclusive remedy once a court has determined that a defendant's right to a speedy trial has been violated?
Opinions:
Majority - Burger, C.J., announced by Douglas, J.
Yes, the Sixth Amendment's guarantee of a speedy trial requires the dismissal of an indictment as the exclusive remedy once a court has determined that a defendant's right to a speedy trial has been violated. The Court affirmed that because the Government did not file a cross-petition to challenge the Court of Appeals' determination that Strunk was denied a speedy trial, the sole question before the Supreme Court was the propriety of the remedy. The Court noted that while Barker v. Wingo described dismissal as an “unsatisfactorily severe remedy” because a defendant who may be guilty goes free, it also unequivocally stated that dismissal must remain “the only possible remedy.” The Court reasoned that a speedy trial violation is unlike other Sixth Amendment guarantees that can be cured by a new trial (e.g., lack of public trial or impartial jury). A prolonged delay causes emotional stress and uncertainty, especially regarding the prospect of concurrent sentences, which a prompt trial removes. The Court acknowledged that stress might be less for an already confined prisoner, but noted other factors like rehabilitation could be adversely affected. The remedy fashioned by the Court of Appeals (sentence reduction) does not address these difficulties. The “flexible” standards mentioned in Barker pertained to the determination of whether a speedy trial denial occurred, not to the remedy for such a denial. The ultimate responsibility for delays, even unintentional ones due to understaffing, rests with the government, and the public interest along with the constitutional guarantee commands prompt disposition of criminal charges.
Analysis:
This case firmly establishes the singular, mandatory remedy for a Sixth Amendment speedy trial violation: dismissal of the charges. By rejecting the Court of Appeals' attempt to fashion a 'practical' remedy, the Supreme Court emphasized the fundamental nature of the speedy trial right and the inability to 'cure' its violation through lesser means. This ruling places a significant burden on the government to ensure timely prosecution and discourages judicial attempts to mitigate the consequences of governmental delay, thereby reinforcing the constitutional right's importance as a protective measure for the accused, even if it means a potentially guilty defendant goes free without a trial. It highlights the unique character of the speedy trial right compared to other procedural guarantees, which often allow for a new trial as a curative measure.
