Without this right, criminal defendants could be held indefinitely under a cloud of unproven criminal accusations. The right to a speedy trial also is crucial to ensuring that a criminal defendant receives a fair trial. If too much time elapses between the alleged crime and the trial, witnesses may die or leave the area, their memories may fade, and physical evidence may be lost.
The Sixth Amendment is ratified as part of the Bill of Rights of the U.S. Constitution. The amendment guarantees the rights of the accused in criminal prosecutions.
In Beavers v. Haubert, the U.S. Supreme Court holds that “speedy” when referring to the Sixth Amendment right to a speedy and public trial does not always mean right away. There may be reasons for some delays.
In Pollard v. United States, the U.S. Supreme Court concludes that in cases in which a delay in sentencing a defendant did not happen on purpose, but by accident, and where it was quickly taken care of, the Sixth Amendment has not been violated.
In United States v. Ewell, the U.S. Supreme Court again says that “speedy” is a relative term. In Ewell, the defendants had been indicted on certain drug charges, then convicted and sentenced. When the defendants appealed, the original indictments were thrown out because they were not prepared correctly. Nineteen months after the original indictments, the government brought new, corrected indictments on the same charges. The Court finds that this 19-month delay is not a violation of the Sixth Amendment’s speedy trial right because the defendants were not just sitting in prison; they were using the court system to be heard. The Court rules that rushing that process would be just as damaging as intentionally delaying it.
In Klopfer v. North Carolina, the U.S. Supreme Court rules that the Sixth Amendment’s right to a speedy trial is so fundamental that it applies to trials in state courts as well as those in federal courts.
In Barker v. Wingo, the U.S. Supreme Court concludes there is no set amount of time for a trial to qualify as “speedy.” Instead, the court rules that a number of factors must be used to decide whether the Sixth Amendment right was violated: (1) length of the delay, (2) reason for the delay, (3) the defendant’s request for the right (that is, did he or she protest during the delay), and (4) whether the delay hurt the defendant’s ability to receive a fair trial. For example, even a short delay might be unconstitutional if the trial was delayed on purpose and, as a result, a defendant’s opportunity to defend himself or herself has been harmed (for example, if an important witness dies during the delay). A longer delay might not be a violation because it was by accident or due to uncontrollable events (like a full court calendar) and because no witnesses or evidence have been lost during the delay. The court hearing the speedy trial claim has to look at all the factors and balance them to reach a fair outcome.
In Strunk v. United States, the U.S. Supreme Court rules that if the Sixth Amendment’s speedy trial right is violated, then the Court must dismiss the indictment against the defendant or reverse the conviction. This means that even if a defendant is guilty of the crime, a violation of the speedy trial right demands that he or she be set free.
To ease the backlog of federal court cases, Congress enacts the Speedy Trial Act of 1974, which establishes specific time limits between various stages of criminal proceedings. For example, the act requires an information or indictment to be filed within 30 days of a defendant’s arrest. The law exempts certain types of delays. For example, a delay caused by the unavailability of a key witness would be exempt.
In Nixon v. Warner Communications Inc., the U.S. Supreme Court rejects an argument by ABC, CBS, NBC and other broadcasters that they are entitled under the Sixth Amendment to obtain complete copies of audiotapes made by the Nixon White House. The tapes, made in the Oval Office, recorded conversations that were used as evidence in the Watergate prosecutions of high-level White House officials. Only certain parts had been played for the jury and introduced as evidence. The broadcasters wanted all of the tapes to be released so they could report on the parts that had not been made public. The Court says the guarantee to a public trial only goes as far as what the reporters saw and heard at the trial.
In Doggett v. United States, the U.S. Supreme Court rules that an 8½-year delay between the government’s indictment of a defendant and the defendant’s arrest violates the defendant’s Sixth Amendment right to a speedy trial. The court rules that even though the delay was not planned or on purpose, it was so long that the reason did not matter. The court says that although sloppiness, incompetence or other unintentional reasons for delays are not taken as seriously as intentional reasons, they still can cross the line. If the delay is very long, as in this case, then the accused does not need to show that his or her case was harmed (for example, that evidence is lost or witnesses are unreachable). Instead, the court assumes harm has been done unless the prosecution can prove otherwise.
In Zedner v. United States, the U.S. Supreme Court finds that a federal defendant’s rights under the Speedy Trial Act of 1974 were violated when he signed a statement in which he waived any future right to a speedy trial. He later tried to assert his right and have his indictment dropped. The Court says the statute does not allow for such a waiver.