United States v. Marion case brief summary
404 U.S. 307 (1971)
CASE FACTS
The trial court had dismissed the indictment for lack of speedy prosecution and the United States objected directly to the United States Supreme Court pursuant to 18 U.S.C.S. § 3731. The Court was asked to decide whether dismissal of a federal indictment was constitutionally required under the speedy trial provisions of U.S. Constitutional Amendment VI, because three years had elapsed between the occurrence of defendants' alleged criminal acts and the filing of the indictment charging them.
DISCUSSION
CONCLUSION
The trial court's decision was reversed based on the court's holding that the constitutional guarantee of a speedy trial did not apply until defendants were indicted and, therefore, any pre-indictment delay in this case did not justify dismissal of the indictment on speedy trial grounds.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
404 U.S. 307 (1971)
CASE SYNOPSIS
The United States sought review of a
decision from the United States District Court for the District of
Columbia, which held that dismissal of a federal indictment was
constitutionally required under U.S. Constitutional Amendment
VI, because three years elapsed between the occurrence of the alleged
criminal acts and the filing of the indictment.CASE FACTS
The trial court had dismissed the indictment for lack of speedy prosecution and the United States objected directly to the United States Supreme Court pursuant to 18 U.S.C.S. § 3731. The Court was asked to decide whether dismissal of a federal indictment was constitutionally required under the speedy trial provisions of U.S. Constitutional Amendment VI, because three years had elapsed between the occurrence of defendants' alleged criminal acts and the filing of the indictment charging them.
DISCUSSION
- After finding jurisdiction, the Court reversed the judgment of the trial court.
- According to the Court, the speedy trial provisions did not apply until defendants, in some way, were officially accused, an event that occurred in this case only when defendants were indicted.
- Because the pre-indictment delay did not extend beyond the period of the applicable statute of limitations, and defendants showed no actual prejudice resulting from the delay, the Court also held that defendants' due process claims were speculative and premature.
- However, the Court noted that such claims could be raised again if actual prejudice could be shown after trial.
CONCLUSION
The trial court's decision was reversed based on the court's holding that the constitutional guarantee of a speedy trial did not apply until defendants were indicted and, therefore, any pre-indictment delay in this case did not justify dismissal of the indictment on speedy trial grounds.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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