Betterman v. Montana
136 S. Ct. 1609
| SCOTUS | 2016Background
- Brandon Betterman pleaded guilty to bail-jumping after failing to appear on domestic-assault charges and was jailed awaiting sentence.
- He spent over 14 months in custody between conviction (guilty plea) and sentencing, much of the delay attributable to institutional procedures (presentence report, motions, scheduling).
- Betterman argued the postconviction delay violated his Sixth Amendment right to a speedy trial.
- The Montana Supreme Court rejected that claim, holding the Speedy Trial Clause does not apply to sentencing delay.
- The U.S. Supreme Court granted certiorari to resolve a circuit/state split and affirmed the Montana Supreme Court.
- The Court left open that other remedies (e.g., due process challenges, statutes, rules) may address excessive sentencing delay, but Betterman did not press a due process claim before the Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Sixth Amendment "Speedy Trial" right extends to delay between conviction (guilty plea) and sentencing | Betterman: the 14-month presentencing delay violated his Sixth Amendment speedy-trial right; sentencing delay should be covered | State/Montana and U.S. Gov: the Speedy Trial Clause protects preconviction phases (arrest/indictment through trial) and detaches at conviction; it does not govern sentencing delay | The Court held the Speedy Trial Clause does not apply after conviction; it protects only through trial/conviction |
| Whether dismissal or a sentence reduction is an appropriate remedy under the Speedy Trial Clause for sentencing delay | Betterman: sought relief tied to the delay (suggested sentence credit reduction) | State: dismissal or vacatur is not appropriate postconviction because the Clause is preconviction-focused; remedies for sentencing delay lie elsewhere | The Court reaffirmed dismissal is the constitutional remedy for a Speedy Trial Clause violation — an inappropriate remedy postconviction — so the Clause offers no tailored sentencing remedy |
| Whether historical/textual evidence supports applying the Clause to sentencing | Betterman: modern plea-dominated system makes sentencing the practical forum for adjudication, so speedy protections should apply | State/majority: historical meaning of "accused" and "trial" contemplates a preconviction right; sentencing is a distinct, postconviction stage | The Court relied on text, history, and precedent to conclude the Clause protects the presumptively innocent and ends at conviction |
| Whether other constitutional or statutory protections address sentencing delay | Betterman: did not press a due process challenge in this Court | State/U.S. Gov: statutes, rules, and the Due Process Clause may furnish relief; Rule 32(b) and state laws require sentencing without unnecessary delay | The Court held other safeguards exist (rules, statutes, due process) but expressed no view on a due process claim because it was not presented |
Key Cases Cited
- United States v. Marion, 404 U.S. 307 (1971) (Speedy Trial Clause attaches at arrest/accusation)
- Barker v. Wingo, 407 U.S. 514 (1972) (speedy-trial balancing test and purposes of the Clause)
- Klopfer v. North Carolina, 386 U.S. 213 (1967) (historical roots of speedy-trial right)
- United States v. Lovasco, 431 U.S. 783 (1977) (due process as safeguard against prejudicial prosecutorial delay pre-arrest)
- Strunk v. United States, 412 U.S. 434 (1973) (dismissal as remedy for speedy-trial violations)
- In re Winship, 397 U.S. 358 (1970) (presumption of innocence and burden of proof principles)
- Mempa v. Rhay, 389 U.S. 128 (1967) (right to counsel extending to some postconviction proceedings)
- United States v. Loud Hawk, 474 U.S. 302 (1986) (Speedy Trial Act implements Sixth Amendment protections)