Jonathan Edward Boyer v. Louisiana
The Supreme Court dismissed this case without deciding the question it had agreed to hear, ruling instead that the writ of certiorari was improvidently granted.
The case had asked whether delay caused by a state's failure to fund an indigent defendant's lawyer should count against the state in a speedy-trial analysis, but a dispute over what actually caused the seven-year delay led the Court to walk away without resolving that legal question.
How it got here: A Louisiana appeals court rejected Boyer's speedy-trial claim; the Supreme Court agreed to review it but then dismissed the case as improvidently granted.
The Case in Depth
What happened
Jonathan Boyer was arrested in 2002 for a killing during a robbery and charged with a capital offense in Louisiana. His case sat for years while courts sorted out how Louisiana would pay his defense attorney, a dispute prosecutors eventually resolved by dropping the death penalty. Boyer was tried more than seven years after his arrest and convicted of lesser offenses; he argued the delay violated his right to a speedy trial.
The question before the Court
Should the years a Louisiana man spent in jail awaiting trial because the state couldn't pay his lawyer count against the state in deciding if his speedy trial right was violated?
Why it matters
Defendants and lower courts get no new guidance on how to treat delay caused by underfunded public defense systems in speedy-trial cases. Louisiana's indigent defense funding crisis, which the dissent says has repeatedly delayed trials statewide, remains unaddressed by the Court, leaving the issue to be litigated case by case in lower courts.
What changes now
The dismissal leaves the Louisiana appellate court's ruling against Boyer's speedy-trial claim in place, and the broader legal question about how to weigh state-funding delays in speedy-trial cases remains unresolved by the Supreme Court. This is a final disposition of this case at the Supreme Court, though it decides nothing about the underlying constitutional question. Lower courts will continue to apply existing speedy-trial precedent case by case.
What this does not decide
The Court did not decide whether delay caused by a state's failure to fund an indigent defendant's lawyer must be weighed against the state in speedy-trial cases. The per curiam order resolves nothing about that legal question; it only reflects the majority's view that the case's facts did not present that issue cleanly.
Concurrences and dissents
Concurrence — Justice Alito
Justice Alito, joined by Justices Scalia and Thomas, agreed the writ was improvidently granted because the record showed the premise of the question presented was false. He detailed how most of the seven-year delay resulted from continuances the defense itself requested, other defense motions, and events like hurricanes, not from any failure by Louisiana to fund Boyer's defense.
Dissent — Justice Sotomayor
“Conditions of this kind cannot persist without endangering constitutional rights.”Sotomayor warns about Louisiana's broader indigent-defense funding problems.
Justice Sotomayor, joined by Justices Ginsburg, Breyer, and Kagan, argued the Court should have answered the question presented rather than dismiss the case. She said the Louisiana courts had found that most of the delay was caused by the state's funding failure, and that under existing precedent such delay must be weighed against the state. She would have remanded for the state court to redo its analysis under the correct standard, and separately raised concerns about broader funding problems in Louisiana's indigent defense system.
How the Court got there
The legal reasoning, step by step
- The Court had granted review to decide whether delay caused by a state's failure to fund a defendant's lawyer should be weighed against the state under the four-factor speedy-trial balancing test from a 1972 case, which looks at length of delay, the reason for delay, the defendant's assertion of the right, and prejudice to the defendant.
- The premise of that question was that a breakdown in Louisiana's funding system caused most of the multi-year delay in this case.
- After reviewing the record, the Court concluded that the premise did not hold up: much of the delay stemmed from repeated continuances requested by the defense itself and other events outside anyone's control, not from the state's failure to pay defense counsel.
- Because the factual basis for the legal question had turned out to be mistaken, the Court determined there was no sound vehicle for deciding the funding-delay question it had agreed to take up.
Doctrinal impact
Cases affected by this decision
Reaffirms Barker v. Wingo (407 U. S. 514)
The dissent relies on this case's four-factor speedy-trial balancing test as still-controlling law.