Crosby v. United States
Headline: Court bars trying defendants in absentia who abscond before trial begins, preventing courts from starting a full criminal trial without the defendant present at its commencement and protecting the right to be there.
Holding:
- Prevents courts from starting full criminal trials when defendants abscond before trial begins.
- Requires judges to delay or reschedule trials when defendants are not present at commencement.
- Makes convictions after pretrial absences vulnerable to reversal.
Summary
Background
Michael Crosby, charged in Minnesota with mail fraud for selling veteran medallions, was released on a $100,000 bond and told his trial date. He attended pretrial meetings but did not appear when trial was scheduled to start. After several days and a fruitless search, the District Court forfeited his bond, found his absence knowing and deliberate, and began the trial with his lawyer participating; a jury later convicted him. The Court of Appeals upheld the convictions, and the Supreme Court agreed to review the question about trial-in-absentia rules.
Reasoning
The Court examined Federal Rule of Criminal Procedure 43, which says a defendant must be present at every stage of trial “except as otherwise provided by this rule.” The Rule allows trial to continue when a defendant who was initially present voluntarily leaves after trial has begun. The Court explained that the Rule does not authorize starting a full trial when the defendant was not there at the outset. The opinion relied on the Rule’s language, historical practice requiring a defendant’s presence, and the logic that an initial presence helps assure any waiver of the right is knowing. The Court reversed the appeals court and remanded for further proceedings, and it did not resolve Crosby’s separate constitutional claim.
Real world impact
Courts may not begin a full criminal trial when a defendant absconds before the trial starts. Judges must delay, reschedule, or take other steps rather than try the case to verdict in the defendant’s absence, and convictions after such trials face reversal.
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