United States v. MacDonald (1981)
- Docket
- 80-1582
- Decided
- 1981-01-01
Summary
Question: Was MacDonald’s Sixth Amendment right to a speedy trial violated by the gap between the 1972 CID’s report recommending further investigation into MacDonald and the re-filing of those same charges in 1975? Conclusion: No. Chief Justice Warren E. Burger delivered the opinion for the 6-3 majority. The Court held that the speedy trial guarantee of the Sixth Amendment is intended to protect citizens from the extended disruptions that may accompany being charged with a crime, such as social stigma, anxiety, and the financial burden of defending oneself in court. In the current case, these interests were not being infringed during the period between the original dismissal and the re-filing of the murder charges because MacDonald was not under arrest, in custody, or subject to any criminal prosecution. Though the situation may have led to stress or other adverse consequence, once the original charges had been dismissed, MacDonald was in the same position as he would have been if charges had never been filed. The Court held that MacDonald could not claim his Sixth Amendment right was being infringed after the dismissal of the original charges. In his concurring opinion, Justice John Paul Stevens wrote that MacDonald’s right to a speedy trial was not suspended during the period between the original dismissal and re-filing. However, the importance of allowing the Government to be cautious before prosecuting MacDonald for such a serious crime meant that the delay did not violate MacDonald’s right to a speedy trial. Justice Thurgood Marshall dissented and argued that the majority opinion failed to take certain facts into account when determining the original charges and the re-filed charges were distinct events between which MacDonald’s right to a speedy trial was not implicated. Not only did the investigation not end when the original charges were dismissed, but MacDonald was also aware the investigation was ongoing. Multiple times between 1972 and 1974, MacDonald requested the Government complete its investigation and even offered to sit for further interviews. Furthermore, the Government never offered any legitimate reason for the delay in re-filing the charges. Neither the language of the Sixth Amendment nor Supreme Court precedent supported the majority’s narrow view of when a criminal prosecution is taking place. Justice William J. Brennan, Jr. and Justice Harry A. Blackmun joined in the dissent.