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Strunk v. United States
United States Supreme Court
412 U.S. 434 (1973)
A federal jury convicted Clarence Strunk (defendant) of transporting a stolen automobile from Wisconsin to Illinois. The federal district court sentenced Strunk to five years of incarceration, which would run at the same time as a one-to-three-year sentence that Strunk was already serving for a prior state conviction. The district court denied Strunk’s pretrial motion to dismiss the case because the approximately 10-month delay between Strunk’s arrest and trial violated Strunk’s right to a speedy trial. Strunk did not testify and presented no witnesses. Strunk appealed, and the appellate court reversed the district court, holding that Strunk was denied a speedy trial but that Strunk’s proposed remedy of dismissal of the charges was too extreme, especially because Strunk did not challenge the sufficiency of the evidence against him or cite any reason why the violation prejudiced the presentation of his defense. Instead, the appellate court remanded the case to the district court to reduce Strunk’s sentence by 259 days to compensate for the unnecessary delay between Strunk’s indictment and arraignment. The United States Supreme Court granted Strunk’s petition for certiorari. The government (plaintiff) did not cross-petition the appellate court’s determination that Strunk was denied a speedy trial, so the only issue before the Supreme Court was whether dismissal of charges or some other remedy was appropriate to redress a speedy-trial-right violation.
Rule of Law
Holding and Reasoning (Burger, C.J.)
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