Betterman v. Montana
Headline: Court rules speedy-trial right ends at conviction, allowing more leeway for post-conviction sentencing delays and leaving other rules or due process to address lengthy sentencing waits for defendants.
Holding: The Court decided the Sixth Amendment speedy-trial guarantee does not apply after a defendant is convicted, so it does not cover delays between conviction and sentencing.
- Prevents using the Sixth Amendment to challenge delays between conviction and sentencing.
- Leaves defendants to pursue state rules, sentencing statutes, or due process claims.
- Acknowledges presentence reports and procedures justify some reasonable delay before sentencing.
Summary
Background
Brandon Betterman, charged after failing to appear on domestic assault matters, pleaded guilty to bail jumping and was jailed more than 14 months before sentencing. Much of the delay stemmed from preparing a presentence report and slow scheduling. He was ultimately sentenced to seven years, with four years suspended, and he argued that the delay violated his right to a speedy trial. The Montana Supreme Court rejected that claim, and the U.S. Supreme Court agreed to resolve the question.
Reasoning
The single question was whether the Sixth Amendment speedy-trial guarantee covers the period after a defendant is convicted but before sentence is imposed. The Court held it does not. The majority explained that the speedy-trial right protects the presumptively innocent from the harms of prolonged accusation, and that right attaches at arrest or charge and ends at conviction. The Court pointed to history, existing federal and state speedy-trial rules, and the fact that the usual remedy for a speedy-trial violation—dismissal—fits only preconviction delays. The Court also noted that presentence investigation and review commonly require some reasonable delay.
Real world impact
As a result, defendants generally cannot use the Sixth Amendment to challenge sentencing delays. Instead, they must rely on statutes, court rules that require timely sentencing, or on due process claims where appropriate. The Court did not decide any due process standard because Betterman did not press such a claim here.
Dissents or concurrances
Justices Thomas and Sotomayor wrote separately: Thomas agreed but reserved broader due process questions; Sotomayor emphasized that due process might be evaluated using flexible factors like those in Barker v. Wingo.
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