Why is the case important?
Government prosecutes petitioner Marc Gilbert Doggett on drug charges eight and one half years after he was indicted.
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.”
Does an eight and one half year delay between indictment and prosecution violate a criminal defendant’s right to a speedy trial?
Yes. Reverse and remand.
Reverse the conviction because the eight and one half year delay was sufficient to trigger the speedy trial inquiry. Also, the Federal Government offered nothing to show that they were not negligent in seeking the individual.
The United States Supreme Court held that the delay between petitioner’s indictment and arrest violated his Sixth Amendment right to a speedy trial. According to the Court, petitioner’s claim met the Barker v. Wingo criteria for evaluating speedy trial claims. First, the extraordinary 8 1/2-year lag between his indictment and arrest clearly sufficed to trigger the speedy trial inquiry. Second, the Government was to blame for the delay. The District Court’s finding that the Government was negligent in pursuing petitioner should be viewed with considerable deference, and neither the Government nor the record provided any reason to reject that finding. Third, petitioner asserted in due course his right to a speedy trial. The courts below found that he did not know of his indictment before his arrest, and, in the factual basis supporting his guilty plea, the Government essentially conceded this point. Finally, the negligent delay between petitioner’s indictment and arrest presumptively prejudiced his ability to prepare an adequate defense. The Court averred that under the circumstances, it was reversible error for the Court of Appeals to hold that the individual’s speedy trial claim had to fail due to the individual’s failure to show actual prejudice, as the Government’s egregious persistence in failing to prosecute the individual was sufficient to warrant relief even without a showing of particularized trial prejudice.
- Case Brief: 1992
- Petitioner: Marc Gilbert Doggett
- Respondent: United States
- Decided by: Rehnquist Court
Citation: 505 US 647 (1992)
Argued: Oct 9, 1991
ReArgued: Feb 24, 1992
Decided: Jun 24, 1992
Granted Feb 25, 1991