Barker v. Wingo
Barker v. Wingo is a significant Supreme Court case that addresses the right to a speedy trial, a fundamental component of the U.S. legal system. The case involved defendants Barker and Manning, who were charged with a serious crime. Due to the strength of the case against Manning, his trial occurred first, leading to a prolonged delay of five years before Barker's trial commenced. After being convicted, Barker appealed, arguing that the extensive delay violated his rights. The Supreme Court, led by Justice Lewis F. Powell, Jr., unanimously rejected this claim, citing a balancing test that considered the reasons for the delay and the lack of prejudice against Barker. The decision sparked public disagreement, ultimately contributing to legislative changes, including the Speedy Trial Act of 1974, which established stricter timelines for federal trials. This case highlights the complexities of balancing defendants' rights and the practicalities of the judicial process.
Barker v. Wingo
Date: June 22, 1972
Citation: 407 U.S. 514
Issue: Right to speedy trial
Significance: To decide whether a trial was delayed for an unreasonable period of time, the Supreme Court established a balancing test with four factors: length of the delay, reasons for the delay, the defendant’s assertion of the right to a speedy trial, and prejudice to the defendant from the delay.
Two defendants, Barker and Manning, were charged with a brutal murder. Because the case against Manning was very strong, he was tried first, then he was to be a witness in Barker’s trial. As a result of difficulties in prosecuting Manning, the trial of Barker was delayed for five years from the time of his arrest. After being found guilty, Barker appealed on the grounds that the long delay violated his right to a speedy trial. His lawyers referred to Dickey v. Florida (1970), in which an eight-year delay had been found to be unconstitutional.
The Supreme Court unanimously rejected Barker’s claim. Justice Lewis F. Powell, Jr.’s opinion for the majority was based on a balancing test. The delay of the trial, while long, was not unreasonable in view of the unavailability of an important witness; the defendant had been slow to register objections to the delay; and there was no evidence that the delay caused any prejudice in the trial.
Much of the public disagreed with the Barker opinion. In 1974 Congress passed the Speedy Trial Act, requiring federal trials to take place one hundred days after an arrest. Most states have enacted similar laws.