United States v. MacDonald
456 U.S. 1 (1982)
Rule of Law:
The Sixth Amendment's Speedy Trial Clause does not apply to the period of time after the government, acting in good faith, has formally dismissed charges against a person. The constitutional protection is only activated when formal criminal charges are pending.
Facts:
- In February 1970, Jeffrey MacDonald's pregnant wife and two young daughters were murdered at their home on the Fort Bragg military reservation.
- MacDonald, an Army Medical Corps captain, was found at the scene with multiple stab wounds.
- MacDonald claimed that several intruders attacked his family and knocked him unconscious.
- Physical evidence at the scene contradicted MacDonald's account, leading investigators to suspect he committed the murders.
- On May 1, 1970, the U.S. Army formally charged MacDonald with the three murders.
- Following a preliminary military hearing, the Commanding General accepted a recommendation to dismiss all charges against MacDonald on October 23, 1970.
- The Army granted MacDonald an honorable discharge in December 1970, and he moved to California to resume his medical practice.
- At the request of the Department of Justice, the Army's Criminal Investigation Division (CID) continued its investigation, eventually leading to a civilian grand jury indictment against MacDonald for the murders on January 24, 1975.
Procedural Posture:
- MacDonald moved to dismiss the indictment in the U.S. District Court for the Eastern District of North Carolina on speedy trial grounds.
- The District Court, as the court of first instance, denied MacDonald's motion.
- The U.S. Court of Appeals for the Fourth Circuit, an intermediate appellate court, permitted an interlocutory appeal and reversed the District Court, ruling the delay violated MacDonald's right.
- The U.S. Supreme Court reversed the Court of Appeals, holding that a defendant could not appeal a denial of a speedy trial motion until after trial.
- On remand, MacDonald was tried and convicted in the District Court on two counts of second-degree murder and one count of first-degree murder.
- After his conviction, MacDonald appealed to the U.S. Court of Appeals for the Fourth Circuit, where a divided panel (appellant: MacDonald, appellee: United States) again found a speedy trial violation and dismissed the indictment.
- The U.S. Supreme Court granted certiorari to review this post-conviction decision.
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Issue:
Does the Sixth Amendment's Speedy Trial Clause apply to the period between the good-faith dismissal of military charges and a subsequent civilian indictment for the same criminal conduct?
Opinions:
Majority - Chief Justice Burger
No. The Sixth Amendment's Speedy Trial Clause does not apply to the period after the government, acting in good faith, formally dismisses charges against an individual. The protections of the Clause are triggered only by a formal indictment or arrest. Citing United States v. Marion, the Court explained that the speedy trial guarantee is designed to minimize the possibility of lengthy pretrial incarceration, reduce the impairment of liberty for those on bail, and shorten the disruption of life caused by unresolved criminal charges. Once charges are dismissed, a person is no longer an 'accused' and suffers no more restraint on their liberty or public obloquy than any other person under criminal investigation. Any prejudice or undue delay occurring during this interim period must be scrutinized under the Due Process Clause, which requires a showing of bad faith or actual prejudice, not the Speedy Trial Clause.
Dissenting - Justice Marshall
Yes. The Speedy Trial Clause should continue to protect a person who has been publicly accused, had charges dismissed, and is then re-charged by the same sovereign for the same crime. A natural reading of the Sixth Amendment does not require that charges be continuously pending for the right to apply. The majority's conclusion is a 'facile' one that ignores the reality that the special anxiety, public obloquy, and financial strain of a public accusation do not disappear simply because charges are formally dropped, especially when the defendant knows an investigation is ongoing. This ruling creates a serious potential for abuse, allowing the government to indefinitely delay a second prosecution for reasons of 'indifference, negligence, or ineptitude' without constitutional consequence under the Speedy Trial Clause.
Concurring - Justice Stevens
Yes. The constitutional right to a speedy trial was not suspended during the period between the Army's dismissal of charges and the subsequent civilian indictment. While agreeing with the dissent's reasoning on the applicability of the Speedy Trial Clause, the interest in allowing the government to proceed cautiously and deliberately before prosecuting a serious offense like murder is of decisive importance in this specific case. Therefore, despite the Clause's applicability, the delay was not constitutionally unacceptable, and the judgment of the Court of Appeals should be reversed.
Analysis:
This decision establishes a clear, bright-line rule that the Sixth Amendment's speedy trial clock stops upon the good-faith dismissal of charges and does not restart until new charges are filed. It significantly narrows the scope of the Speedy Trial Clause, shifting the burden onto defendants to prove a Due Process violation for any delay between indictments, which typically requires showing both actual prejudice to their defense and bad faith by the government. The ruling gives prosecutors greater flexibility to drop weak cases, conduct further investigation without the pressure of the speedy trial clock, and refile charges later. This formalistic approach prioritizes the official status of an 'accused' over the continuous anxiety and disruption a person may experience while under a known, ongoing investigation.
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