Dickey v. Florida

Background

A man named Robert Dickey was arrested on a state armed-robbery charge from 1960 but was held in federal custody and not returned for trial until 1968. He repeatedly asked Florida authorities in 1962, 1963, and 1966 to bring him back for trial or withdraw the State's detainer. The state delayed, brought him back in 1968, tried him, and convicted him based largely on an eyewitness identification; he claimed the delay harmed his defense. The Florida Supreme Court had earlier said a State must act diligently once it chooses to charge, but Gadsden County still did not promptly secure him.

Reasoning

The Court addressed whether the seven-year delay denied Dickey his constitutional right to a speedy trial. The majority found no valid reason for the lengthy postponement, noted actual prejudice — two defense witnesses died, another became unavailable, and police records were lost — and concluded the delay was for the State's convenience rather than necessity. Because Dickey was available and had repeatedly demanded trial, the Court reversed his conviction and directed dismissal of proceedings arising from the 1960 charges.

Real world impact

The ruling holds that when an accused is available and repeatedly demands trial, the State has a duty to act diligently to secure the defendant for prompt prosecution; failure can lead to dismissal. It protects defendants whose defenses are impaired by long delays and warns prosecutors that unexplained or unnecessary postponements, with loss of witnesses or records, can defeat prosecutions.

Dissents or concurrances

Justice Brennan (joined by Marshall) wrote separately to discuss how courts should measure speedy-trial claims; Justice Harlan concurred but preferred resolving these claims under the Fourteenth Amendment’s due process framework.