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Concept
Zedner v. United States
Summary
Zedner v. United States, 547 U.S. 489 (2006), was a United States Supreme Court case involving the right to a speedy trial. Justice Samuel Alito, writing for a unanimous Court, ruled that a defendant cannot prospectively waive the protections of the Speedy Trial Act. Justice Antonin Scalia filed a partial concurrence, objecting to Alito's use of legislative history.
Jacob Zedner was arrested in 1996 for attempting to open bank accounts with a fake $10 Million bond issued by the fictitious “Ministry of Finance of U.S.A.” He was indicted by a grand jury in the Eastern District of New York for trying to pass counterfeit Treasury securities on April 4, 1996. The District Court granted a continuance until September 6, then granted another continuance until November 8. Due to difficulties in arranging a trial schedule, the judge suggested that the defendant waive his rights under the Speedy Trial Act "for all time." The defendant and his attorney agreed to do so.
The case continued to languish for the next four years, during which time the defendant changed lawyers, was examined by a psychiatrist, and ultimately decided to proceed pro se. On March 7, 2001, while his competency to stand trial was being examined, the defendant moved to have the case dismissed for failure to comply with the Speedy Trial Act. The District Court denied his motion, and on April 7, 2003, the trial finally began.
On April 7, 2003, after a trial in the District Court, a jury found Zedner guilty and the judge sentenced him to 63 months imprisonment. The United States Court of Appeals for the Second Circuit upheld the verdict, including the waiver of speedy trial rights, and noted that any error was harmless. The Supreme Court granted certiorari to determine if the waiver was effective.
The Speedy Trial Act requires that a trial begin within seventy days of the indictment, but provides for a variety of exceptions. If the trial does not begin on time, the defendant may move for dismissal, which the court must (under most circumstances) grant.
Official source
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