Zedner v. United States

Facts of the Case

In April 1996, defendant was indicted for allegedly attempting to open accounts at financial institutions using counterfeit United States bonds. In November, defendant requested an adjournment and signed a waiver of his rights under the Speedy Trial Act for all time. The district court granted defendant another continuance in January 1997, continuing the case for 91 days. Subsequent proceedings delayed defendant’s trial until 2003. The district court convicted defendant of attempting to defraud a financial institution in violation of 18 U.S.C.S. § 1344. The appellate court affirmed defendant’s conviction. The Supreme Court of the United States reversed the appellate court’s judgment and remanded the case for further proceedings.

Question

(1) May a defendant waive his right to a speedy trial under the Speedy Trial Act of 1974? (2) May Zedner, who had previously signed a waiver of his rights under the Act, later base an appeal on the fact that such a waiver was invalid? (3) And was the judge’s failure to exempt the 91-day period on the record harmless error?

CONCLUSION

No, yes, and no. In an opinion by Justice Samuel Alito, the Supreme Court unanimously held that a defendant may not simply waive his right to a speedy trial under the Act. The list of acceptable reasons for an ends-of-justice order by the judge includes specific mention of the defendant’s need for time to obtain counsel and prepare his case. If the defendant could simply waive his rights under the Act in order to meet these needs, the judge would not need to give them special consideration.

Case Information

  • Citation: 547 US 489 (2006)
  • Granted: Jan 6, 2006
  • Argued: Apr 18, 2006
  • Decided Jun 5, 2006