## Facts

- Brandon Thomas Betterman was charged in Montana with partner or family member assault and failed to appear for a court date, leading to a warrant.
- He later turned himself in and was charged with bail jumping.
- On April 19, 2012, Betterman pleaded guilty to bail jumping.
- Betterman remained in county jail for over 14 months before sentencing occurred on January 17, 2013; the delay was largely institutional or administrative rather than attributable to Betterman.
- The court sentenced Betterman to seven years’ imprisonment, with four years suspended.

## Issues

1. Whether the Sixth Amendment Speedy Trial Clause applies to delay between conviction (including a guilty plea) and sentencing.
2. Whether a 14-month post-plea delay in holding a sentencing hearing can violate the Sixth Amendment right to a speedy trial.

## Decision

- The Supreme Court unanimously affirmed the Montana Supreme Court.
- The Court held that the Sixth Amendment’s speedy trial guarantee does not apply after a defendant has been found guilty at trial or has pleaded guilty.
- Because the Speedy Trial Clause is inapplicable postconviction, the Court did not evaluate whether the 14-month delay would be unreasonable under speedy-trial standards.
- The Court indicated that protection against excessive sentencing delay may arise from the Due Process Clause and from rules requiring sentencing without unnecessary delay, but it did not decide any due process claim in this case.

## Legal Principles

- The Sixth Amendment Speedy Trial Clause protects an “accused” from arrest or formal charge through conviction; it detaches upon conviction.
- The speedy-trial guarantee is tied to preconviction concerns such as limiting prolonged pretrial incarceration, reducing anxiety from public accusation, and preventing impairment of the defense.
- Extending the Speedy Trial Clause to sentencing would conflict with its established remedy (dismissal of charges) by potentially vacating valid convictions based solely on sentencing delay.
- Postconviction, presentencing delay may be subject to constitutional review under due process and constrained by procedural rules requiring prompt sentencing, though the precise due process standard was not set.

## Conclusion

The Court held that there is no Sixth Amendment right to speedy sentencing because the Speedy Trial Clause ends at conviction; claims based on delayed sentencing must rely on due process or other prompt-sentencing requirements rather than the Speedy Trial Clause.


Betterman v. Montana, 578 U.S. 437 (2016)