Betterman v. Montana, 578 U.S. ___ (2016)

Issues: ,



NOTE:?Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued.The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader.See United States v. Detroit Timber & Lumber Co., 200 U.?S. 321 .



certiorari to the supreme court of montana

No. 14?1457.?Argued March 28, 2016?Decided May 19, 2016

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One-Sentence Takeaway:?The Sixth Amendment?s speedy trial guarantee does not apply once a defendant has been found guilty at trial or has pleaded guilty to criminal charges.



Petitioner Brandon Betterman pleaded guilty to bail jumping after failing to appear in court on domestic assault charges. He was then jailed for over 14 months awaiting sentence, in large part due to institutional delay. He was eventually sentenced to seven years? imprisonment, with four of the years suspended. Arguing that the 14-month gap between conviction and sentencing violated his speedy trial right, Betterman appealed, but the Montana Supreme Court affirmed the conviction and sentence, ruling that the Sixth Amendment?s Speedy Trial Clause does not apply to postconviction, presentencing delay.

Held:?The Sixth Amendment?s speedy trial guarantee does not apply once a defendant has been found guilty at trial or has pleaded guilty to criminal charges. Pp.?3?11.

(a)?Criminal proceedings generally unfold in three discrete phases. First, the State investigates to determine whether to arrest and charge a suspect. Once charged, the suspect is presumed innocent until conviction upon trial or guilty plea. After conviction, the court imposes sentence. There are checks against delay geared to each particular phase. P.?3.

(b)?Statutes of limitations provide the primary protection against delay in the first stage, when the suspect remains at liberty, with the Due Process Clause safeguarding against fundamentally unfair prosecutorial conduct. United States v. Lovasco, 431 U.?S. 783 . P.?3.

(c)?The Speedy Trial Clause right attaches when the second phase begins, that is, upon a defendant?s arrest or formal accusation.United States v. Marion, 404 U.?S. 307 ?321. The right detaches upon conviction, when this second stage ends. Before conviction, the accused is shielded by the presumption of innocence, Reed v. Ross, 468 U.?S. 1 , which the Speedy Trial Clause implements by minimizing the likelihood of lengthy incarceration before trial, lessening the anxiety and concern associated with a public accusation, and limiting the effects of long delay on the accused?s ability to mount a defense, Marion, 404 U.?S., at 320. The Speedy Trial Clause thus loses force upon conviction.

This reading comports with the historical understanding of the speedy trial right. It ?has its roots at the very foundation of our English law heritage,? Klopfer v. North Carolina, 386 U.?S. 213 , and it was the contemporaneous understanding of the Sixth Amendment?s language that ?accused? described a status preceding ?convicted? and ?trial? meant a discrete episode after which judgment (i.e.,sentencing) would follow. The Court?s precedent aligns with the text and history of the Speedy Trial Clause. See Barker v. Wingo, 407 U.?S. 514 ?533. Just as the right to speedy trial does not arise prearrest, Marion, 404 U.?S., at 320?322, adverse consequences of postconviction delay are outside the purview of the Speedy Trial Clause. The sole remedy for a violation of the speedy trial right?dismissal of the charges?fits the preconviction focus of the Clause, for it would be an unjustified windfall to remedy sentencing delay by vacating validly obtained convictions. This reading also finds support in the federal Speedy Trial Act of 1974 and numerous state analogs, which impose time limits for charging and trial but say nothing about sentencing. The prevalence of guilty pleas and the resulting scarcity of trials in today?s justice system do not bear on the presumption-of-innocence protection at the heart of the Speedy Trial Clause. Moreover, a central feature of contemporary sentencing?the preparation and review of a presentence investigation report?requires some amount of wholly reasonable presentencing delay. Pp.?3?9.

(d)?Although the Constitution?s presumption-of-innocence-protective speedy trial right is not engaged in the sentencing phase, statutes and rules offer defendants recourse. Federal Rule of Criminal Procedure 32(b)(1), for example, directs courts to ?impose sentence without unnecessary delay.? Further, as at the prearrest stage, due process serves as a backstop against exorbitant delay. Because Betterman advanced no due process claim here, however, the Court expresses no opinion on how he might fare under that more pliable standard. Pp.?9?11.

378 Mont. 182, 342 P.?3d 971, affirmed.

Ginsburg, J., delivered the opinion for a unanimous Court. Thomas, J., filed a concurring opinion, in which Alito, J., joined. Sotomayor, J., filed a concurring opinion.