United States v. MacDonald

1982-03-31

Headline: Court limits speedy-trial protections, ruling delays after dismissed criminal charges do not count under the Sixth Amendment, affecting defendants later indicted after an earlier dismissal.

Holding: The Court ruled that the Sixth Amendment’s speedy-trial right does not cover delays occurring after criminal charges have been dismissed; such post-dismissal delays are evaluated under the Due Process Clause, not the speedy-trial guarantee.

Real World Impact:

Stops counting post-dismissal time toward Sixth Amendment speedy-trial limits.
Allows prosecutors more time to reopen investigations before civilian indictment.
Leaves unfair-delay challenges to general due process review in lower courts.

Topics: speedy trial, pretrial delay, military and civilian prosecutions, due process

Summary

Background

A physician who served as an Army captain was accused after his wife and two young children were murdered at Fort Bragg. The Army charged him, held an Article 32 hearing with 56 witnesses, and then dismissed the military charges in October 1970; the Justice Department later asked the Army to continue investigating and a civilian grand jury returned an indictment in January 1975. The defendant was tried, convicted, and raised a speedy-trial objection based on the long interval between the military dismissal and the later civilian indictment.

Reasoning

The central question was whether the time after the Army dismissed its charges counts toward the Sixth Amendment right to a speedy trial. The Court held that the Sixth Amendment protection applies only while formal charges are pending; once charges are dismissed, the speedy-trial guarantee no longer applies and any later delay must be judged under general fairness protections of the Due Process Clause, not the speedy-trial rule. The opinion relied on earlier rulings and the Speedy Trial Act’s text, reversed the Fourth Circuit’s dismissal, and remanded for further proceedings.

Real world impact

This ruling means people whose initial charges were dismissed are not guaranteed that the time until a later indictment will count under the Sixth Amendment; prosecutors and investigators may reopen inquiries without that time automatically counting against speedy-trial limits. Other claims — for example, that the delay was so unfair as to violate due process — were left to lower courts and were not decided here.

Dissents or concurrances

Justice Stevens joined the judgment but stressed caution for prosecutors in serious cases. Justice Marshall (joined by Justices Brennan and Blackmun) dissented, arguing the speedy-trial right continued after dismissal and that a roughly 26-month unexplained delay violated the defendant’s rights.