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Supreme Court Decision Update - Zedner v. United States

supreme3.jpgThe second of today’s Supreme Court cases, Zedner v. United States (PDF of the Opinion), deals with the fascinating Speedy Trial Act, and whether a defendant can waive his right to a speedy trial even if it goes against the public’s interest in the prompt prosecution of criminal indictments.

Quizlaw Analysis: The Supremes basically rule that the right to a speedy trial is not just in the interest of a criminal defendant but that it’s also in the public’s best interest. Therefore, courts cannot allow defendants to waive their right to a speedy trial unless the reasons for the delay are permitted under the Speedy Trial Act.

Back in 2003, Jacob Zedner was convicted of six counts of attempting to defraud a financial institution - crimes originally brought against him in federal court in 1996. Zedner appealed his conviction under the Speedy Trial Act, which requires that a defendant’s trial commence within 70 days from the date of indictment. Failure to meet this deadline requires dismissal of the indictment.

After Zedner was indicted in 1996, there were a series of delays. The first delay was actually requested by Zedner in November 1996. However, because the court had a full docket and feared that Zedner would invoke his rights under the Speedy Trial Act, the court requested that Zedner condition the delay on a waiver of his speedy trial rights “for all time.” Zedner requested several other delays over the next few years and the court never addressed whether these delays were permitted under the Speedy Trail Act, allowing the delays based on Zedner’s waiver of his Speedy Trial Act claims “for all time.”

Zedner eventually made it to trial and, after he was convicted, he argued on appeal that his Speedy Trial Act rights were violated. The trail court and the Second Circuit both denied his appeal, noting that the delays were caused partly by Zedner’s own behavior or granted upon his own request.

The Supreme Court, in a unanimous decision written by Justice Alito, reversed the lower courts’ decision, holding that a “defendant may not prospectively waive the application of the Act” and, therefore, Zedner’s waiver “for all time” was ineffective. The Supremes stated that a defendant does not have a right to “opt out” of the Act. To procure a continuance, a defendant must offer a reason specifically provided for under the Act, such as to have more time to acquire an attorney or prepare for the case. The Court also noted that a defendant could not merely waive his rights to a speedy trial because that right is not only the in the defendant’s best interest - it also serves the public interest. Moreover, prospective waivers such as Zedner’s don’t work because, in many cases, “the prosecution, defense, and court would all like to opt out, to the detriment of the public interest.” Therefore, because the continuance exceeded the 70-day delay allowed under the Act, Zedner’s speedy trial rights were violated.

The contrary Justice Scalia wrote his own opinion, agreeing with the Court’s ultimate judgment, but disagreeing with the majority of the Court’s decision to rely upon the Speedy Trial Act’s legislative history, noting that the use of “legislative history is illegitimate and ill-advised in the interpretation of any statute” because the statute’s meaning should be plain on its face.

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