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Keywords

defendantappealtrialmotion
defendantjurisdictionattorneyappealtrialwillprosecutorrespondent

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New York v. Hill, 528 U.S. 110, 120 S.Ct. 659, 145 L.Ed.2d 560, 68 USLW 4029, 00 Cal. Daily Op. Serv. 239, 2000 Daily Journal D.A.R. 307, 2000 CJ C.A.R. 173, 13 Fla. L. Weekly Fed. S 35

Facts

The defendant was an Ohio prisoner against whom New York lodged a detainer under the IAD. After signing a request for disposition of the detainer, he was returned to New York to face charges of murder and robbery. Defense counsel agreed to a trial date set beyond the 180-day period specified by the IAD. Following the defendant's conviction, he moved to dismiss the indictment, arguing that the IAD's time limit had expired. The trial court denied the motion, concluding that the defense counsel's agreement constituted a waiver of the defendant's rights under the IAD.

On January 9, 1995, the prosecutor and defense counsel appeared in court to set a trial date. The following colloquy ensued: '[Prosecutor]: Your Honor, [the regular attorney] from our office is engaged in a trial today. He told me that the Court was to set a trial date today. I believe the Court may have preliminarily discussed a May 1st date, and [the regular attorney] says that would fit in his calendar.' '[Defense Counsel]: That will be fine, Your Honor.'

Issue

Whether defense counsel's agreement to a trial date outside the time period required by the IAD bars the defendant from seeking dismissal of the indictment on the grounds that trial did not occur within that period.

This case presents the question whether defense counsel's agreement to a trial date outside the time period required by Article III of the Interstate Agreement on Detainers bars the defendant from seeking dismissal because trial did not occur within that period.

Rule

The IAD requires that a prisoner be brought to trial within 180 days of a request for disposition, but allows for continuances for good cause shown in open court, with the presence of the prisoner or his counsel.

Upon such a request, the prisoner 'shall be brought to trial within one hundred eighty days,' 'provided that for good cause shown in open court, the prisoner or his counsel being present, the court having jurisdiction of the matter may grant any necessary or reasonable continuance.'

Analysis

The court analyzed the implications of the IAD and the nature of waiver in the context of scheduling decisions made by defense counsel. It determined that scheduling matters are typically within the purview of counsel, and that requiring the defendant's express assent for routine scheduling would be impractical. The court emphasized that the IAD's provisions allow for good-cause continuances, which can be agreed upon by counsel, thus supporting the notion that counsel's agreement to a trial date beyond the IAD period does not automatically waive the defendant's rights.

This case does not involve a purported prospective waiver of all protection of the IAD's time limits or of the IAD generally, but merely agreement to a specified delay in trial.

Conclusion

The New York Court of Appeals reversed the lower courts' decisions and ordered the indictment to be dismissed, holding that defense counsel's agreement to a later trial date did not waive the defendant's IAD speedy trial rights.

The judgment of the New York Court of Appeals is reversed.

Who won?

The defendant prevailed in the case because the court found that his rights under the IAD were not waived by his counsel's agreement to a later trial date.

The New York Court of Appeals, however, reversed and ordered that the indictment against respondent be dismissed; defense counsel's agreement to a later trial date, it held, did not waive respondent's speedy trial rights under the IAD.

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