Doggett v. United States
Citation
505 U.S. 647 (1992)
Facts
Marc Doggett was indicted for federal drug charges in 1980. Unknown to Doggett, a warrant was issued for his arrest. Due to government negligence — the DEA failed to track him despite his open, law-abiding life — Doggett was not arrested until 1988, eight and a half years after indictment. During this entire period, Doggett was unaware of the outstanding charges. When finally arrested, he moved to dismiss for violation of his Sixth Amendment right to a speedy trial.
Issue
Does an eight-and-a-half-year delay between indictment and arrest — caused by government negligence rather than deliberate delay — violate the Sixth Amendment right to a speedy trial, even absent proof of actual prejudice to the defendant’s case?
Holding
Yes. The Supreme Court held, 5–4, that the delay violated Doggett’s speedy trial right under the Barker v. Wingo balancing test.
Rule / Doctrine
Barker v. Wingo four-factor test: (1) length of delay (trigger for inquiry at one year); (2) reason for delay (deliberate, negligent, or valid); (3) defendant’s assertion of the right; (4) prejudice to the defendant. An extraordinary delay caused by government negligence, even without proof of actual prejudice, generates presumptive prejudice sufficient to tip the balance in the defendant’s favor.
Significance
Doggett establishes that negligent government delay — not just deliberate delay — can violate the speedy trial right, and that prejudice can be presumed rather than proved in cases of extraordinary delay. This limits the government’s ability to be passive about locating defendants on pending indictments without consequence.