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Moore v. Arizona

U.S.
Nov 5, 1973
414 U.S. 25 (1973)

Summary

holding that a three year delay warranted remand for an assessment, under Barker

Summary of this case from State v. Brillon

Opinion

ON PETITION FOR WRIT OF CERTIORARI TO THE SUPREME COURT OF ARIZONA

No. 73-5002.

Decided November 5, 1973

Where petitioner was tried for murder in Arizona almost three years after he was charged and 28 months after he first demanded that Arizona either extradite him from California, where he was serving a prison term, or drop a detainer against him, the Arizona Supreme Court, in affirming the denial of petitioner's pretrial habeas corpus application, erred in ruling that a showing of prejudice to the defense at trial was essential to establish a federal speedy trial claim. In addition to possible prejudice, a court must weigh the reasons for delay in bringing an incarcerated defendant to trial, and should also consider the possible impact pending charges might have on defendant's prospects for parole and meaningful rehabilitation. Smith v. Hooey, 393 U.S. 374; Dickey v. Florida, 398 U.S. 30; Barker v. Wingo, 407 U.S. 514.

Certiorari granted; 109 Ariz. 111, 506 P.2d 242, vacated and remanded.


Almost three years after he was charged and 28 months after he first demanded that Arizona either extradite him from California, where he was serving a prison term, or drop a detainer against him, petitioner was tried for murder in Arizona. Prior to trial, he filed a state habeas corpus application, alleging a deprivation of his Sixth and Fourteenth Amendment right to a speedy trial. In affirming the denial of the petition, the Arizona Supreme Court ruled that under this Court's decisions in Dickey v. Florida, 398 U.S. 30 (1970), and Barker v. Wingo, 407 U.S. 514 (1972), a showing of prejudice to the defense at trial was essential to establish a federal speedy trial claim. The state court found no such prejudice here because petitioner was afforded a preliminary hearing and allowed to subpoena witnesses. 109 Ariz. 111, 506 P.2d 242 (1973).

The court did not mention the unavailability of one of the two key witnesses as the result of her deportation 18 months after the charge had been filed against petitioner.

The state court was in fundamental error in its reading of Barker v. Wingo and in the standard applied in judging petitioner's speedy trial claim. Barker v. Wingo expressly rejected the notion that an affirmative demonstration of prejudice was necessary to prove a denial of the constitutional right to a speedy trial:

"We regard none of the four factors identified above [length of delay, reason for delay, defendant's assertion of his right, and prejudice to the defendant] as either a necessary or sufficient condition to the finding of a deprivation of the right of speedy trial. Rather, they are related factors and must be considered together with such other circumstances as may be relevant. In sum, these factors have no talismanic qualities; courts must still engage in a difficult and sensitive balancing process. But, because we are dealing with a fundamental right of the accused, this process must be carried out with full recognition that the accused's interest in a speedy trial is specifically affirmed in the Constitution." 407 U.S., at 533 (footnote omitted).

In addition to possible prejudice, any court must thus carefully weigh the reasons for the delay in bringing an incarcerated defendant to trial. In the face of petitioner's repeated demands, did the State discharge its "constitutional duty to make a diligent, good-faith effort to bring him [to trial]"? Smith v. Hooey, 393 U.S. 374, 383 (1969).

Moreover, prejudice to a defendant caused by delay in bringing him to trial is not confined to the possible prejudice to his defense in those proceedings. Inordinate delay,

The examples of possible trial prejudice recited in Barker bear directly on this case: "If witnesses die or disappear during a delay, the prejudice is obvious. There is also prejudice if defense witnesses are unable to recall accurately events of the distant past. Loss of memory, however, is not always reflected in the record because what has been forgotten can rarely be shown." Barker v. Wingo, 407 U.S. 514, 532 (1972).

"wholly aside from possible prejudice to a defense on the merits, may `seriously interfere with the defendant's liberty, whether he is free on bail or not, and . . . may disrupt his employment, drain his financial resources, curtail his associations, subject him to public obloquy, and create anxiety in him, his family and his friends.' United States v. Marion, 404 U.S. 307, 320 (1971). These factors are more serious for some than for others, but they are inevitably present in every case to some extent, for every defendant will either be incarcerated pending trial or on bail subject to substantial restrictions on his liberty." Barker v. Wingo, supra, at 537 (WHITE, J., concurring).

See also id., at 532-533 (majority opinion). Some of these factors may carry quite different weight where a defendant is incarcerated after conviction in another State, but no court should overlook the possible impact pending charges might have on his prospects for parole and meaningful rehabilitation. Strunk v. United States, 412 U.S. 434, 439 (1973).

The State of Arizona itself has conceded that this is a close case under Barker v. Wingo and that it is arguable whether the three-year delay was excusable. Because we agree and because "the right to a speedy trial is as fundamental as any of the rights secured by the Sixth Amendment," Klopfer v. North Carolina, 386 U.S. 213, 223 (1967), we grant the motion for leave to proceed in forma pauperis and the petition, vacate the judgment, and remand to the Arizona Supreme Court to reassess petitioner's case under the standards mandated by Smith, Barker, and Dickey.

So ordered.


Summaries of

Moore v. Arizona

U.S.
Nov 5, 1973
414 U.S. 25 (1973)

holding that a three year delay warranted remand for an assessment, under Barker

Summary of this case from State v. Brillon

holding that the state court committed a "fundamental error" in concluding that a showing of prejudice to the defense at trial was essential to establishing a speedy-trial claim

Summary of this case from State v. Brillon

finding "fundamental error" in a ruling by the Arizona Supreme Court that a showing of prejudice to the defense at trial was essential to establish a federal speedy trial claim

Summary of this case from Graves v. United States

reversing state court ruling that prejudice to the defense at trial was essential to establish a federal speedy trial claim

Summary of this case from Graves v. United States

recognizing that delay "may seriously interfere with the defendant's liberty, whether he is free on bail or not, and may disrupt his employment, drain his financial resources, curtail his associations, subject him to public obloquy, and create anxiety in him, his family and his friends" (quotation marks, alteration and citation omitted)

Summary of this case from U.S. v. Brown

recognizing that "prejudice to a defendant caused by delay in bringing [them] to trial is not confined to the possible prejudice to [their] defense in those proceedings."

Summary of this case from People v. Bonds

recognizing that actionable "prejudice to a defendant caused by delay . . . is not confined to the possible prejudice to his defense"

Summary of this case from State v. Brillon

In Moore, this Court held that a defendant's speedy trial claim should not have been dismissed without further hearing, where the defendant was tried three years after he was first charged and 28 months after he demanded a speedy trial.

Summary of this case from United States v. MacDonald

noting that " Barker v. Wingo expressly rejected the notion that an affirmative demonstration of prejudice was necessary to prove a denial of the constitutional right to a speedy trial"

Summary of this case from Smith v. La Clair

emphasizing that prejudice in the speedy trial context is "not confined to the possible prejudice to defense" but includes, among other things, the defendant's anxiety

Summary of this case from Goodrum v. Quarterman

In Moore v. Arizona, 414 U.S. 25, 94 S.Ct. 188, 38 L.Ed.2d 183 (1973), the Supreme Court stated that the Barker v. Wingo factors assume a different (presumably lesser) stature where the defendant is incarcerated after conviction, but explicitly rejected the notion that prejudice is confined to possible impairment of the defense at trial.

Summary of this case from Burkett v. Fulcomer

In Moore v. Arizona, 414 U.S. 25, 27, 94 S.Ct. 188, 190, 38 L.Ed.2d 183 (1973) (per curiam), the Court recognized that public accusation "`may disrupt [the defendant's] employment, drain his financial resources, curtail his associations, subject him to public obloquy, and create anxiety in him, his family and his friends,'" (quoting Barker v. Wingo, 407 U.S. at 537, 92 S.Ct. at 2195 (White, J., concurring)), and held that this form of prejudice must be considered in ascertaining whether there has been a speedy trial violation.

Summary of this case from Government of Virgin Islands v. Pemberton

In Moore v. Arizona, 414 U.S. 25, 94 S.Ct. 188, 38 L.Ed.2d 183 (1973) (per curiam), the Court held that under Barker a defendant need not in every case establish prejudice to his ability to defend on the charges at trial to establish a speedy trial clause violation.

Summary of this case from Takacs v. Engle

In Moore, the Supreme Court held that prejudice to a defendant caused by delay in bringing him to trial was not confined to possible prejudice to his defense caused by the delay.

Summary of this case from Nowland v. Dir., TDCJ-ID

In Moore v. Arizona, 414 U.S. 25, 94 S.Ct. 188, 38 L.Ed.2d 183 (1973) (per curiam), the Supreme Court reiterated the need to balance the factors enunciated in Barker.

Summary of this case from Cowgill v. Zimmerman

In Moore, the Supreme Court found a three-year delay from charge to trial to be a "close case under Barker v. Wingo" and remanded for further consideration of all of the Barker factors.

Summary of this case from Cowgill v. Zimmerman

In Moore v. Arizona, 414 U.S. 25, 26, 94 S.Ct. 188, 38 L.Ed.2d 183 (1973) the Supreme Court stated that proof of prejudice to a defendant's case is not essential to a successful speedy trial claim under the sixth amendment.

Summary of this case from United States v. Rowbotham

In Moore v. Arizona, 414 U.S. 25, 26, 94 S.Ct. 188, 38 L.Ed.2d 183 (1973), the Supreme Court rejected as "fundamental error" the Arizona Supreme Court’s ruling that a showing of actual prejudice to the trial defense was essential to the establishment of a federal speedy trial violation.

Summary of this case from Henderson v. Commonwealth

emphasizing that no single factor is a necessary or sufficient condition to the finding of a constitutional speedy trial violation

Summary of this case from Tate v. State

stating that courts should inquire whether the state "discharge[d] its `constitutional duty to make a diligent, good-faith effort to bring [the defendant to trial]'" (quoting Smith v. Hooey, 393 U.S. 374, 384, 89 S.Ct. 575, 21 L.Ed.2d 607 (1969))

Summary of this case from State v. Ariegwe

pending charges may affect defendant's chances for "parole and meaningful rehabilitation"

Summary of this case from Turner v. U.S.

In Moore v. Arizona, 414 U.S. 25, 26-27, 94 S.Ct. 188, 189-190, 38 L.Ed.2d 183 (1973), the Supreme Court acknowledged the debilitating effect of delay on a defendant's financial, societal, and emotional circumstances.

Summary of this case from Ross v. State

In Moore v. Arizona, 414 U.S. 25, 94 S.Ct. 188, 38 L.Ed.2d 183 (1973), the U.S. Supreme Court noted that a defendant may be prejudiced in numerous ways by a delay in bringing him to trial.

Summary of this case from Trotter v. State

In Moore, 414 U.S. at 26, 94 S.Ct. at 189, the Supreme Court said, " Barker v. Wingo expressly rejected the notion that an affirmative demonstration of prejudice was necessary to prove a denial of the constitutional right to a speedy trial."

Summary of this case from Harvey v. State

In Moore, the Court was reviewing an Arizona Supreme Court interpretation of Barker and its predecessors, where the Arizona Supreme Court held that prejudice to the defense at trial was necessary to establish a federal speedy trial claim.

Summary of this case from Phillips v. State
Case details for

Moore v. Arizona

Case Details

Full title:MOORE v . ARIZONA

Court:U.S.

Date published: Nov 5, 1973

Citations

414 U.S. 25 (1973)
94 S. Ct. 188

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