Supreme Court of the United States
Vermont v. Brillon
March 9, 2009556 U.S. 81
Summary
The Court reversed the Vermont Supreme Court’s judgment because that court treated delays caused by appointed defense counsel as attributable to the State and did not adequately account for Brillon’s conduct in the overall speedy-trial balance. Delays caused by defense counsel are generally attributed to the defendant, whether counsel is retained or appointed, absent a systemic breakdown in the public defender system; the record showed no such breakdown.
Holding
- Attribution of delay caused by appointed defense counsel. Delay caused by defense counsel is generally attributable to the defendant, even when counsel is publicly appointed; the Vermont Supreme Court erred by attributing delay to the State merely because assigned counsel failed to move the case forward.
- Consideration of the defendant’s conduct in the speedy-trial balance. A speedy-trial analysis must account for the defendant’s role in the chain of events causing delay; the Vermont Supreme Court erred by assessing counsel’s periods discretely and failing adequately to weigh Brillon’s deliberate efforts to disrupt proceedings.
- Systemic breakdown in the public defender system. Delay resulting from a systemic breakdown in the public defender system may be charged to the State, but the record in this case did not establish that institutional problems caused any part of the delay.
Docket 08-88
Cited authorities
- 92 Harv. L. Rev. 340
- N.Y. Crim. Proc. Law Ann. §30.30