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14-1457 BETTERMAN V. MONTANA DECISION BELOW: 342 P.3d 971 CERT. GRANTED 12/4/2015 QUESTION PRESENTED: Whether the Sixth Amendment's Speedy Trial Clause applies to the sentencing phase of a criminal prosecution, protecting a criminal defendant from inordinate delay in final disposition of his case. LOWER COURT CASE NUMBER: DA 13-0572
In the case of Betterman v. Montana, Brandon Thomas Betterman was charged with bail jumping and spent over 14 months in jail awaiting sentencing after pleading guilty. He argued that this delay violated his Sixth Amendment right to a speedy trial. However, the Supreme Court ruled unanimously against him stating that the Sixth Amendment's Speedy Trial Clause does not extend to delays in sentencing. The court reasoned that the primary purpose of this clause is to limit undue and oppressive incarceration prior to trial, minimize anxiety associated with public accusation and limit possibilities for impairing defense; none of which applies post-conviction or post-guilty plea when there is no presumption of innocence at stake.
In the case of Betterman v. Montana, there was no formal dissenting opinion as the decision by the Supreme Court was unanimous (8-0). The court ruled that constitutional protections against excessive delays in criminal sentencing do not apply once a defendant has been found guilty at trial or pleaded guilty. Justice Ruth Bader Ginsburg wrote for the court and stated that while it is important to prevent undue delay in sentencing, this protection does not fall under the Sixth Amendment's speedy trial guarantee but rather falls under due process provisions.