Doggett v. United States

PETITIONER: Marc Gilbert Doggett
RESPONDENT: United States
LOCATION: District Court for the Middle District of Florida, Jacksonville Division

DOCKET NO.: 90-857
DECIDED BY: Rehnquist Court (1991-1993)
LOWER COURT: United States Court of Appeals for the Eleventh Circuit

CITATION: 505 US 647 (1992)
ARGUED: Oct 09, 1991
REARGUED: Feb 24, 1992
DECIDED: Jun 24, 1992
GRANTED: Feb 25, 1991

ADVOCATES:
Robert S. Mueller, III - for the respondent
William C. Bryson - for the respondent upon reargument
William J. Sheppard - for the petitioner

Facts of the case

In 1980, Marc Gilbert Doggett was indicted in the U.S. District Court for the Middle District of Florida on federal drug charges. When Drug Enforcement Administration (DEA) agents went to his home to arrest him, they found he had left for Colombia four days earlier. The DEA later found out that Doggett was in custody in Panama on unrelated charges. While the Panamanian government promised to expel Doggett back to the United States after the proceedings in Panama were over, Doggett was allowed to continue on to Colombia. The DEA agent in charge did not follow up on the case and Doggett reentered the United States without issue in 1982 where he lived openly under his own name and in accordance with the law. No one looked into Doggett’s whereabouts, but in 1988 a random credit check of individuals with outstanding warrants revealed his place of residence.

After being arrested, Doggett moved to dismiss the indictment, arguing that the government’s failure to prosecute him earlier violated his Sixth Amendment right to a speedy trial. A federal magistrate found that the length of time between indictment and arrest was presumptively prejudicial, but recommended dismissal of Doggett’s motion because he did not show actual prejudice. The district court followed the magistrate’s recommendation. Doggett then entered a conditional guilty plea, allowing him to appeal the subsequent conviction on the speedy trial claim. The U.S. Court of Appeals for the 11th Circuit affirmed.

Question

Should a mandatory requirement of actual prejudice be imposed in order for the accused to prevail on a claim that his right to a speedy trial has been violated?

Has Moore v. Arizona, which holds that an affirmative demonstration of prejudice is not required, been reversed?

Media for Doggett v. United States

Audio Transcription for Oral Argument - October 09, 1991 in Doggett v. United States

Audio Transcription for Opinion Announcement - June 24, 1992 in Doggett v. United States

William H. Rehnquist:

The opinion of the Court in No. 90-857, Doggett against the United States will be announced by Justice Souter.

David H. Souter:

This case comes to us on writ of certiorari to the United States Court of Appeals for the Eleventh Circuit.

In 1980, apparently without knowing that he had been indicted for his role on a drug conspiracy, the petitioner, Mark Doggett, left the United States and traveled to Panama where he was soon jailed on other drug charges.

Federal officials asked Panama to expel him to this country on completion of the proceedings against him there and although Panamanian officials agreed to comply, they failed to do so, and in 1982, they allowed Doggett to leave for Columbia.

From that point on, the government made virtually no effort to track him down and did not know that he returned to the United States a few months after his departure from Panama.

Some six years later, the government finally came across Doggett after he had married, earned a college degree, found steady employment, and had lived openly under his own name.

Doggett moved to dismiss the indictment on the grounds that the government's failure to prosecute him earlier had violated his Sixth Amendment right to a speedy trial.

The District Court denied relief.

Doggett entered a conditional guilty plea and the Court of Appeals later affirmed the District Court's dismissal of the speedy trial claim.

In an opinion filed with the Clerk today, applying the criteria for accessing speedy trial claims that we announced 20 years ago in Barker and Wingo, we reverse.

The eight-and-a-half year delay between Doggett's indictment and arrest clearly suffices to trigger the speedy trial inquiry as the lower courts explicitly found the government caused six years of this delay by its negligent failure to track Doggett down.

We accept the lower court's finding that Doggett did not know of his outstanding indictment and we therefore, do not fall him for failing to assert his right to a speedy trial until after his arrest.

We view the extraordinary length of Doggett's pretrial delay as sufficient to place his ability to mount a successful defense at trial in serious jeopardy.

We hold that such presumptive prejudice is sufficient to carry a speedy trial claim when the government is at fault fro negligently causing a delay of such extraordinary length.

Justice O'Connor has written a dissenting opinion; Justice Thomas has also written a dissenting opinion in which the Chief Justice and Justice Scalia have joined.