Cases by Issue - Speedy Trial

Zedner v. United States

Mon, 05 Jan 2009 17:45:18 +0000

Case Basics

Docket No.

05-5992

Petitioner

Jacob Zedner

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Roberts Court (2006-2009)

Decided By

Roberts Court (2006-2009)

Opinion

547 U.S. ___ (2006)

Granted

Friday, January 6, 2006

Argued

Tuesday, April 18, 2006

Decided

Monday, June 5, 2006

Advocates

Edward Scott Zas (argued the cause for Petitioner)

Daryl Joseffer (argued the cause for Respondent)

Facts of the Case

Under the Speedy Trial Act of 1974, a federal criminal trial must begin within 70 days of the defendant's arrest or first appearance in court. The Act includes a list of delays which do not count toward this 70-day period, and one of these acceptable delays occurs when a federal district court finds on the record that the "ends of justice" served by granting a delay outweigh the public's and defendant's interest in a speedy trial. In this case, Zedner was a defendant in a criminal trial and twice asked the district court to issue such an order. The third time he requested one, the district court judge suggested that he sign a waiver of his right to a speedy trial under the Act for all time. Zedner signed the form, and accordingly the next time he asked for a delay the judge did not make on-the-record findings exempting the 91-day delay. Four years later, Zedner filed a motion to dismiss based on the failure to comply with the Act's 70-day period that resulted from that 91-day delay. The district court rejected the motion because of the waiver, and the Second Circuit Court of Appeals affirmed. Zedner appealed to the Supreme Court, arguing that the waiver he signed was invalid under the Act.

Question

(1) May a defendant waive his right to a speedy trial under the Speedy Trial Act of 1974? (2) May Zedner, who had previously signed a waiver of his rights under the Act, later base an appeal on the fact that such a waiver was invalid? (3) And was the judge's failure to exempt the 91-day period on the record harmless error?

Conclusion

Decision: 9 votes for Zedner, 0 vote(s) against
Legal provision: 18 U.S.C. 3161

No, yes, and no. In an opinion by Justice Samuel Alito, the Supreme Court unanimously held that a defendant may not simply waive his right to a speedy trial under the Act. The list of acceptable reasons for an "ends-of-justice" order by the judge includes specific mention of the defendant's need for time to obtain counsel and prepare his case. If the defendant could simply waive his rights under the Act in order to meet these needs, the judge would not need to give them special consideration.

Doggett v. United States

Mon, 05 Jan 2009 16:24:23 +0000

Case Basics

Docket No.

90-857

Petitioner

Doggett

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1991)

Decided By

Rehnquist Court (1991-1993)

Opinion

505 U.S. 647 (1992)

Argued

Wednesday, October 9, 1991

Reargued:

Monday, February 24, 1992

Decided

Wednesday, June 24, 1992

Advocates

Robert S. Mueller, III (on behalf of the Respondent)

William J. Sheppard (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Doggett, 4 vote(s) against
Legal provision: Speedy Trial

None

United States v. Taylor

Mon, 05 Jan 2009 17:25:43 +0000

Case Basics

Docket No.

87-573

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Taylor

Respondent Type

Respondent

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

487 U.S. 326 (1988)

Argued

Monday, April 25, 1988

Decided

Friday, June 24, 1988

Advocates

Edwin S. Kneedler (on behalf of the Petitioner)

Ian G. Loveseth (on behalf of Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for United States, 3 vote(s) against
Legal provision: 18 U.S.C. 3162

None

Henderson v. United States

Mon, 05 Jan 2009 17:27:10 +0000

Case Basics

Docket No.

84-1744

Petitioner

Henderson

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

476 U.S. 321 (1986)

Argued

Tuesday, April 1, 1986

Decided

Monday, May 19, 1986

Advocates

Roger Clegg (on behalf of the respondent)

Denise Anton (on behalf of the petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: 18 U.S.C. 3161

None

United States v. Loud Hawk

Mon, 05 Jan 2009 17:26:55 +0000

Case Basics

Docket No.

84-1361

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Loud Hawk

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

474 U.S. 302 (1986)

Argued

Tuesday, November 12, 1985

Decided

Tuesday, January 21, 1986

Advocates

Bruce M. Kuhlik (on behalf of the petitioner)

Kenneth H. Stern (on behalf of the respondents)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: Speedy Trial

None

United States v. Von Neumann

Mon, 05 Jan 2009 17:26:55 +0000

Case Basics

Docket No.

84-1144

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Von Neumann

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

474 U.S. 242 (1986)

Argued

Monday, November 4, 1985

Decided

Tuesday, January 14, 1986

Advocates

Charles L. Birke (on behalf of the Respondent)

Alan I. Horowitz (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Due Process

None

United States v. Rojas-Contreras

Mon, 05 Jan 2009 17:27:23 +0000

Case Basics

Docket No.

84-1023

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Rojas-Contreras

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

474 U.S. 231 (1985)

Argued

Wednesday, October 9, 1985

Decided

Monday, December 16, 1985

Advocates

Judy Clare Clarke (on behalf of the respondent (Appointed by this Court))

Patty Merkamp Stemler (on behalf of the petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 18 U.S.C. 3161

None

United States v. $8,850

Mon, 05 Jan 2009 17:32:43 +0000

Case Basics

Docket No.

81-1062

Petitioner

United States

Petitioner Type

Petitioner

Respondent

$8,850

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

461 U.S. 555 (1983)

Argued

Tuesday, January 18, 1983

Decided

Monday, May 23, 1983

Advocates

Victor Sherman (on behalf of the Respondent)

Andrew L. Frey (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Due Process

None

United States v. Macdonald

Mon, 05 Jan 2009 17:30:52 +0000

Case Basics

Docket No.

80-1582

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Macdonald

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

456 U.S. 1 (1982)

Argued

Monday, December 7, 1981

Decided

Wednesday, March 31, 1982

Advocates

Ralph S. Spritzer (on behalf of the Respondent)

Alan I. Horowitz (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for United States, 3 vote(s) against
Legal provision: Speedy Trial

None

United States v. Macdonald

Mon, 05 Jan 2009 16:34:11 +0000

Case Basics

Docket No.

75-1892

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Macdonald

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

435 U.S. 850 (1978)

Argued

Monday, January 9, 1978

Decided

Monday, May 1, 1978

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 0 vote(s) against
Legal provision: Speedy Trial

None

United States v. Lovasco

Mon, 05 Jan 2009 17:10:04 +0000

Case Basics

Docket No.

75-1844

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Lovasco

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

431 U.S. 783 (1977)

Argued

March 21-22, 1977

Decided

Thursday, June 9, 1977

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Speedy Trial

None

Strunk v. United States

Mon, 05 Jan 2009 17:19:43 +0000

Case Basics

Docket No.

72-5521

Petitioner

Strunk

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

412 U.S. 434 (1973)

Argued

Tuesday, April 24, 1973

Decided

Monday, June 11, 1973

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Strunk, 0 vote(s) against
Legal provision: Speedy Trial

None

Barker v. Wingo

Mon, 05 Jan 2009 16:32:52 +0000

Case Basics

Docket No.

71-5255

Petitioner

Barker

Petitioner Type

Petitioner

Respondent

Wingo

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

407 U.S. 514 (1972)

Argued

Tuesday, April 11, 1972

Decided

Thursday, June 22, 1972

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Wingo, 0 vote(s) against
Legal provision: Speedy Trial

None

United States v. Marion

Mon, 05 Jan 2009 16:30:50 +0000

Case Basics

Docket No.

70-19

Appellee

Marion

Petitioner Type

Appellee

Appellant

United States

Respondent Type

Appellant

Heard By

Burger Court (1971-1972)

Decided By

Burger Court (1971-1972)

Opinion

404 U.S. 307 (1971)

Argued

Monday, November 8, 1971

Decided

Monday, December 20, 1971

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 0 vote(s) against
Legal provision: Speedy Trial

None

Dickey v. Florida

Mon, 05 Jan 2009 17:39:00 +0000

Case Basics

Docket No.

728

Petitioner

Dickey

Petitioner Type

Petitioner

Respondent

Florida

Respondent Type

Respondent

Heard By

Burger Court (1969-1970)

Decided By

Burger Court (1969-1970)

Opinion

398 U.S. 30 (1970)

Argued

Wednesday, January 21, 1970

Decided

Monday, May 25, 1970

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Dickey, 0 vote(s) against
Legal provision: Speedy Trial

None

Smith v. Hooey

Mon, 05 Jan 2009 17:40:47 +0000

Case Basics

Docket No.

198

Petitioner

Smith

Petitioner Type

Petitioner

Respondent

Hooey

Respondent Type

Respondent

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

393 U.S. 374 (1969)

Argued

Wednesday, December 11, 1968

Decided

Monday, January 20, 1969

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Smith, 0 vote(s) against
Legal provision: Speedy Trial

None

Klopfer v. North Carolina

Mon, 05 Jan 2009 17:42:12 +0000

Case Basics

Docket No.

100

Petitioner

Klopfer

Petitioner Type

Petitioner

Respondent

North Carolina

Respondent Type

Respondent

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

386 U.S. 213 (1967)

Argued

Thursday, December 8, 1966

Decided

Monday, March 13, 1967

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Klopfer, 0 vote(s) against
Legal provision: Speedy Trial

None

United States v. Ewell

Mon, 05 Jan 2009 17:42:47 +0000

Case Basics

Docket No.

Appellee

Ewell

Petitioner Type

Appellee

Appellant

United States

Respondent Type

Appellant

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

383 U.S. 116 (1966)

Argued

Thursday, November 18, 1965

Decided

Wednesday, February 23, 1966

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Speedy Trial

None

Pollard v. United States

Mon, 05 Jan 2009 16:25:48 +0000

Case Basics

Docket No.

Petitioner

Pollard

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1956-1957)

Decided By

Warren Court (1956-1957)

Opinion

352 U.S. 354 (1957)

Argued

Monday, December 3, 1956

Decided

Monday, February 25, 1957

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: Double Jeopardy

None