Betterman v. Montana

136 S.Ct. 1609 (2016)

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Nature of the Case

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Facts

D failed to appear on domestic assault charges and was charged with bail jumping. D pled guilty to the bail-jumping charge. D was jailed for over 14 months awaiting sentence on that conviction. The presentence report took nearly five months to complete; the trial court took several months to deny two presentence motions (one seeking dismissal of the charge on the ground of delay); and the court was slow in setting a sentencing hearing. D was sentenced to seven years’ imprisonment, with four of those years suspended. D appealed. D claimed the 14-month gap between conviction and sentencing violated his speedy trial right. The Montana Supreme Court affirmed. The Supreme Court granted certiorari.