Doggett v. United States (1991)
- Docket
- 90-857
- Decided
- 1991-01-01
Summary
Question: Should a mandatory requirement of actual prejudice be imposed in order for the accused to prevail on a claim that his right to a speedy trial has been violated? Has Moore v. Arizona , which holds that an affirmative demonstration of prejudice is not required, been reversed? Conclusion: No, No. Justice David H. Souter, writing for a 5-4 majority, reversed and remanded. The Supreme Court held that the government’s egregious failure to locate and prosecute Doggett warranted relief even without showing actual prejudice. Doggett was unaware of the indictment prior to be arrested 8 ½ years later, so he could not be penalized for failing to raise the speedy trial defense earlier. Justice Sandra Day O’Connor dissented, arguing that the possibility of prejudice is not enough to prove that the right to a speedy trial has been violated. Justice Clarence Thomas also dissented, arguing that the right to a speedy trial was meant to prevent oppressive incarceration and the anxiety accompanying public accusation. Because Doggett was never incarcerated and had no knowledge of the charges against him until his arrest, neither of those purposes were served by this decision.