Doggett v. United States

505 U.S. 647 (1992)

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Nature of the Case

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Facts

Doggett (D) was indicted on cocaine charges in 1980. However, he soon left the country, and DEA officials were unable to track him down. The DEA knew that he was later imprisoned in Panama, but after requesting that he be extradited back to the United States, never followed up on his status. Once the DEA discovered that he had left Panama for Colombia, it made no further attempt to locate him. Although D returned to the country in 1982, agents took no serious action to find him. By the chance of a simple credit check, they found D in 1988 and arrested him. D moved to dismiss, claiming that the Government (P)'s failure to prosecute him earlier violated his 6th Amendment right to a speedy trial. The Federal Magistrate found that D had made no showing that the delay had impaired his ability to mount a defense or had prejudiced him. The District Court denied D's motion. The court of Appeals affirmed. The court ruled that D could prevail only by proving 'actual prejudice' or by establishing that 'the first three Barker factors weigh[ed] heavily in his favor.'