Barker v. Wingo
Citation: 407 U.S. 514 (1972)
Facts
Willie Barker’s murder trial was delayed over five years — from 1958 to 1963 — largely because the prosecution wanted to first convict Barker’s codefendant Silas Manning, whose conviction depended on sixteen trials and two reversals. Barker did not assert his speedy trial right until 1962. He was eventually tried and convicted.
Issue
What test governs whether a defendant’s Sixth Amendment right to a speedy trial has been violated?
Holding
The Supreme Court rejected both a fixed-time rule and a demand-waiver rule in favor of a flexible, four-factor balancing test. Barker’s rights were not violated on the facts.
Rule
Courts evaluate speedy trial claims by balancing four factors: (1) the length of the delay; (2) the reason for the delay; (3) whether the defendant asserted the right; and (4) prejudice to the defendant. No single factor is dispositive.
Significance
Barker v. Wingo is the definitive speedy trial case, establishing the multi-factor balancing test that courts still apply. It illustrates the Court’s reluctance to impose bright-line constitutional rules on complex procedural questions, and the test’s flexibility has generated extensive litigation over what counts as prejudice and acceptable delay.