In the case of Strunk, aka Wagner v. United States in 1972, the U.S Supreme Court ruled on an issue related to a delay in trial due to governmental negligence. The petitioner had been indicted for draft evasion but was not brought to trial until four years later because he was mistakenly thought by authorities to be residing outside of the country when he was actually living within it. He argued that this delay violated his Sixth Amendment right to a speedy trial and moved for dismissal of his indictment which was denied by both District Court and Court of Appeals. However, upon reaching the Supreme Court, it held that such delays caused solely by government negligence automatically warranted dismissal regardless if prejudice against defendant could be demonstrated or not.

In the dissenting opinion for Strunk v. United States, Justice William O. Douglas argued that any delay in bringing a defendant to trial should automatically result in dismissal of charges, regardless of whether or not the delay was caused by government negligence or deliberate action. He believed that this strict interpretation of the Sixth Amendment's right to a speedy trial is necessary to prevent potential abuses and ensure justice. In his view, allowing exceptions based on reasons for delays could lead to arbitrary decisions and potentially compromise defendants' rights. Furthermore, he contended that it is unfair for defendants who may be innocent but are forced to live under uncertainty and stress due to prolonged trials.