Facts
- Jeffrey R. MacDonald, a former Army captain and physician, was suspected of murdering his pregnant wife and two children at Fort Bragg, North Carolina.
- In 1970, the Army formally charged MacDonald; after an Article 32 investigation, the military dismissed the charges, and MacDonald was honorably discharged.
- After dismissal, at the Department of Justice’s request, the Army Criminal Investigation Division continued investigating and issued a report in 1972; the Department of Justice later presented the matter to a federal grand jury in 1974.
- In January 1975, a federal grand jury indicted MacDonald for the three murders.
- MacDonald moved to dismiss the indictment on Sixth Amendment speedy-trial grounds; the district court denied the motion.
- After MacDonald was tried and convicted in federal court, the Fourth Circuit held the Sixth Amendment had been violated, relying in part on the time between dismissal of the military charges and the federal indictment, and ordered the indictment dismissed.
Issues
- Whether the Sixth Amendment Speedy Trial Clause permits counting the time between the good-faith dismissal of prior military charges and a later civilian indictment when assessing a speedy-trial violation.
Decision
- The Supreme Court reversed the Fourth Circuit and remanded.
- The Court held the Sixth Amendment speedy-trial right does not apply during periods when no charges are pending.
- The time between dismissal of the military charges and the later federal indictment could not be included in the Sixth Amendment speedy-trial calculation.
- Any claim of prejudicial delay during that post-dismissal investigative period must be evaluated under the Fifth Amendment Due Process Clause (and related statutory limits), not the Sixth Amendment.
Legal Principles
- The Sixth Amendment speedy-trial right attaches only upon formal accusation (e.g., indictment, information, arrest, or other official charges).
- When charges are dismissed in good faith, the Sixth Amendment speedy-trial protection ends for the period in which no charges are pending.
- Pre-indictment delay and post-dismissal investigative delay are not cognizable under the Speedy Trial Clause; they may be challenged, if at all, under due process and statutes of limitations.
- The Speedy Trial Clause is aimed at harms associated with pending charges (e.g., pretrial incarceration, bail-related liberty restraints, and disruption caused by unresolved accusations), not the generalized burdens of being under investigation.
Conclusion
The Court held that the Sixth Amendment’s Speedy Trial Clause does not cover the interval after good-faith dismissal of charges and before a later indictment, so that gap cannot support a speedy-trial dismissal; complaints about investigative delay during such periods must proceed under due process rather than the Speedy Trial Clause.