Zedner v. United States
Encyclopedia
Zedner v. United States, 547 U.S. 489
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (2006), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 case involving the right to a speedy trial
Speedy trial
Speedy trial refers to one of the rights guaranteed by the United States Constitution to defendants in criminal proceedings. The right to a speedy trial, guaranteed by the Sixth Amendment, is intended to ensure that defendants are not subjected to unreasonably lengthy incarceration prior to a fair...

. Justice Samuel Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....

, writing for a unanimous Court, ruled that a defendant cannot prospectively waive the protections of the Speedy Trial Act. Justice Antonin Scalia
Antonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...

 filed a partial concurrence, objecting to Alito's use of legislative history
Legislative history
Legislative history includes any of various materials generated in the course of creating legislation, such as committee reports, analysis by legislative counsel, committee hearings, floor debates, and histories of actions taken...

.

Overview

Jacob Zedner was arrested in 1996 for attempting to open bank accounts with counterfeit
Counterfeit
To counterfeit means to illegally imitate something. Counterfeit products are often produced with the intent to take advantage of the superior value of the imitated product...

 Treasury securities
Treasury security
A United States Treasury security is government debt issued by the United States Department of the Treasury through the Bureau of the Public Debt. Treasury securities are the debt financing instruments of the United States federal government, and they are often referred to simply as Treasuries...

. He was indicted by a grand jury
Grand jury
A grand jury is a type of jury that determines whether a criminal indictment will issue. Currently, only the United States retains grand juries, although some other common law jurisdictions formerly employed them, and most other jurisdictions employ some other type of preliminary hearing...

 in the Eastern District of New York
United States District Court for the Eastern District of New York
The United States District Court for the Eastern District of New York is the federal district court whose jurisdiction comprises the entirety of Long Island and Staten Island...

 on April 4, 1996. The District Court granted a continuance until September 6, then granted another continuance until November 8. Due to difficulties in arranging a trial schedule, the judge suggested that the defendant waive his rights under the Speedy Trial Act "for all time." The defendant and his attorney agreed to do so.

The case continued to languish for the next four years, during which time the defendant changed lawyers, was examined by a psychiatrist
Psychiatry
Psychiatry is the medical specialty devoted to the study and treatment of mental disorders. These mental disorders include various affective, behavioural, cognitive and perceptual abnormalities...

, and ultimately decided to proceed pro se. On March 7, 2001, while his competency to stand trial was being examined, the defendant moved to have the case dismissed for failure to comply with the Speedy Trial Act. The District Court denied his motion, and on April 7, 2003, the trial finally began.

Procedural history

On April 7, 2003, after a trial in the District Court, a jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...

 found Zedner guilty and the judge sentenced him to 63 months imprisonment
Prison
A prison is a place in which people are physically confined and, usually, deprived of a range of personal freedoms. Imprisonment or incarceration is a legal penalty that may be imposed by the state for the commission of a crime...

. The United States Court of Appeals for the Second Circuit
United States Court of Appeals for the Second Circuit
The United States Court of Appeals for the Second Circuit is one of the thirteen United States Courts of Appeals...

 upheld the verdict, including the waiver of speedy trial rights. The Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...

to determine if the waiver was effective.

Issue

The Speedy Trial Act requires that a trial begin within seventy days of the indictment
Indictment
An indictment , in the common-law legal system, is a formal accusation that a person has committed a crime. In jurisdictions that maintain the concept of felonies, the serious criminal offence is a felony; jurisdictions that lack the concept of felonies often use that of an indictable offence—an...

, but provides for a variety of exceptions. If the trial does not begin on time, the defendant may move for dismissal, which the court must (under most circumstances) grant.

Parties' arguments

The government contended that the defendant could waive his rights under the Act. The defendant did so, but then contended that such a waiver was unlawful. The issue had not been addressed in earlier cases.

Opinion of the Court

The Court unanimously held that the defendant was correct; one may not prospectively waive one's rights under the Speedy Trial Act. Justice Alito wrote that the purpose of the Act is not simply to protect the defendant's rights, but to protect the public's interest in a speedy trial. For that reason, the Act excludes certain delays even at the request of the defendant.

Alito next discussed the legislative history of the Act; this is the section in which Justice Scalia declined to concur
Textualism
Textualism is a formalist theory of statutory interpretation, holding that a statute's ordinary meaning should govern its interpretation, as opposed to inquiries into non-textual sources such as the intention of the legislature in passing the law, the problem it was intended to remedy, or...

. The history follows the explicit terms of the Act, stating that the public has an interest in quick resolutions to criminal charges. Alito went on to discuss the lack of a provision for prospective waiver in the statute.

The Court then rejected the government's alternate theory of the case: that the defendant, having agreed to the waiver, is now estopped
Estoppel
Estoppel in its broadest sense is a legal term referring to a series of legal and equitable doctrines that preclude "a person from denying or asserting anything to the contrary of that which has, in contemplation of law, been established as the truth, either by the acts of judicial or legislative...

 from challenging it. The Court declines to apply estoppel doctrines, stating that it would "entirely swallow the Act's no-waiver policy." Furthermore, the Court found, since the district court requested the waiver, rather than the defendant, estoppel is not applicable. In addition, the harmless error
Harmless error
A harmless error is a ruling by a trial judge that, although mistaken, does not meet the burden for a losing party to reverse the original decision of the trier of fact on appeal, or to warrant a new trial. Harmless error is easiest to understand in an evidentiary context...

 doctrine does not apply to speedy trial violations.

Concurrence

Justice Scalia concurred in everything except Part III-A-2, the section on legislative history.

See all


External links

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