Dillingham v. United States
Headline: Court rules that the right to a speedy trial can begin at arrest, reverses lower court, and allows pre-indictment delay after arrest to be counted against the government.
Holding: In a per curiam order, the Court held that the Sixth Amendment’s speedy-trial protection applies when a person is arrested and held, so pre-indictment delay after arrest can be counted and the appeals court was reversed.
- Allows arrested people to count pre-indictment delay in speedy-trial claims.
- Requires prosecutors to justify long delays before filing formal charges.
- May lead courts to dismiss cases where delay caused unfairness.
Summary
Background
A man was arrested on federal charges of automobile theft under 18 U.S.C. §§ 371, 2312, and 2313. He waited 22 months between his arrest and formal indictment and then another 12 months before his trial. After arraignment and again after trial he asked the trial court to dismiss the indictment, saying the long delay violated the Constitution’s right to a speedy trial (meaning to be tried without unnecessary delay). The district court denied those motions, and the Fifth Circuit affirmed, relying on a prior case, United States v. Marion, to treat the pre-indictment gap as not countable without proof of actual harm. The Supreme Court agreed to hear the appeal and allowed the man to proceed without paying fees.
Reasoning
The key question was whether delays that happen after an arrest but before a formal indictment can be counted when someone claims their right to a speedy trial was violated. The Court, in a short unsigned opinion, said yes: an arrest and holding to answer make someone an "accused" and trigger speedy-trial protections because arrest requires probable cause and imposes serious restraints. The Court concluded the Fifth Circuit’s reading of Marion was wrong and reversed the appeals court, sending the case back for further proceedings consistent with this view.
Real world impact
The ruling means people who are arrested and held can count the time before formal charges when arguing they were not tried promptly. Prosecutors and courts will need to explain long pre-indictment delays after arrest. The decision remands the case, so the final outcome may still change.
Dissents or concurrances
The Chief Justice dissented from the Court’s order, expressing disagreement with the per curiam reversal.
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