Klopfer v. North Carolina
Klopfer v. North Carolina is a significant Supreme Court case that addressed the right to a speedy trial as guaranteed by the Sixth Amendment. The case arose when the petitioner, Klopfer, was indicted for criminal trespass due to his participation in a sit-in demonstration at a restaurant. Following a jury's inability to reach a verdict, the trial was declared a mistrial, but the state opted to indefinitely delay any further proceedings against him. Klopfer challenged this delay, claiming it violated his due process rights. Ultimately, the Supreme Court ruled in a 6-3 decision, stating that the state's actions deprived Klopfer of his liberty without due process. This ruling not only reaffirmed the right to a speedy trial but also incorporated this right to the states through the Fourteenth Amendment. The case highlights the balance between individual rights and state procedures, and it has influenced subsequent legal interpretations regarding the timely administration of justice.
Klopfer v. North Carolina
Date: March 13, 1967
Citation: 386 U.S. 213
Issue: Right to a speedy trial
Significance: The Supreme Court applied the Sixth Amendment’s promise of a speedy trial to the states through the Fourteenth Amendment’s due process clause under the incorporation doctrine.
Klopfer had been indicted by North Carolina for criminal trespass for taking part in a sit-in demonstration in a restaurant. At Klopfer’s trial, the jury failed to reach an agreement, and the judge declared a mistrial. This meant the state could retry Klopfer, but the state prosecutor elected to persuade a court to delay the trial indefinitely. Klopfer sued and appealed in all relevant North Carolina courts without success. Finally he appealed to the Supreme Court, which ruled against North Carolina. The 6-3 majority opinion, written by Chief Justice Earl Warren, stated the uncertainty and delay that inevitably resulted from the state’s procedure had deprived Klopfer of his liberty without due process of law. The Court also used the incorporation doctrine to apply the Sixth Amendment guarantee of speedy trial to the states. Justices John M. Harlan II and Potter Stewart dissented. In later cases, the Court often used a balancing test that generally favors the prosecution, as it did in Barker v. Wingo (1972).
