Doggett v. United States
Doggett v. United States is a 1992 United States Supreme Court case involving the Sixth Amendment right to a speedy trial, as applied to the defendant.
Background
The United States indicted Marc Doggett in February 1980 on charges of conspiracy to distribute cocaine. The principal agent for the Drug Enforcement Administration notified the United States Marshals Service that DEA would oversee the arrest of Doggett and his co-conspirators.
One month later, two officers (under DEA's direction) traveled to Raleigh, North Carolina to arrest Doggett, only to learn that he had fled the country for Colombia four days earlier. The agent then notified Customs and several law enforcement agencies, and posted info on a Department of the Treasury database, in an attempt to arrest Doggett upon his return. Unbeknownst to the agent, the Treasury database info expired in September of that year and was not re-entered.
The agent would learn the following September (1981) that Doggett had been arrested in Panama on drug charges. Instead of seeking extradition (believing that Panama would not cooperate), the agent merely asked Panamanian authorities to "expel" Doggett upon his release. Though they promised to comply they did not; when Doggett was released the following July (1982) he was allowed to travel to Colombia. The American Embassy notified the Department of State of this development but State never notified DEA. The agent would not learn of this development until being reassigned to Colombia in 1985; believing that Doggett had settled down in Colombia (and believing that they too would not cooperate with an extradition request) he made no further attempt to track him down.
But instead, Doggett returned to the United States on September 25, 1982, passing through Customs in New York City with no incident. Doggett did not return to the drug trade; instead he settled down in Virginia, married, earned a college degree, found a steady job, lived openly under his own name, and "stayed within the law". Most notably, Doggett was never made aware of the indictment against him. Not until September 1988 when the Marshal's Service ran a credit check on several thousand people, did they find out where Doggett was living; Doggett was finally arrested on September 5 of that year, nearly 8 1⁄2 years after his indictment and almost 6 1⁄2 years after his return to the United States.
Doggett moved to have his indictment dismissed on speedy trial grounds. Using the factors set forth in Barker v. Wingo, a federal magistrate ruled that three of the four factors were in Doggett's favor: the length of time between the indictment and his arrest, the government's negligence in not tracking down Doggett, and that Doggett was not at fault in asserting his right to a speedy trial due to his lack of knowledge that he was charged with a crime until his arrest. However, the magistrate ruled that the delay did not hinder Doggett's ability to mount a successful defense (the fourth factor) and thus recommended to the District Court that the motion be denied, which the Court adopted. Doggett then made a conditional guilty plea, reserving his right to appeal the speedy trial issue. A panel of the Eighth Circuit Court of Appeals upheld the decision; the dissent argued that too much emphasis was placed on the fourth factor.
Resolution
The Court ruled 5-4 to overturn the lower court's decision. Justice Souter, joined by Justices White, Blackmun, Stevens, and Kennedy, determined that the long delay between indictment and arrest violated his right to a speedy trial. Justice Thomas (joined by Chief Justice Rehnquist and Justice Scalia) and Justice O'Connor (writing separately) dissented from the majority.