Zedner V. United States - Opinion of The Court

Opinion of The Court

The Court unanimously held that the defendant was correct; one may not prospectively waive one's rights under the Speedy Trial Act. Justice Alito wrote that the purpose of the Act is not simply to protect the defendant's rights, but to protect the public's interest in a speedy trial. For that reason, the Act excludes certain delays even at the request of the defendant.

Alito next discussed the legislative history of the Act; this is the section in which Justice Scalia declined to concur. The history follows the explicit terms of the Act, stating that the public has an interest in quick resolutions to criminal charges. Alito went on to discuss the lack of a provision for prospective waiver in the statute.

The Court then rejected the government's alternate theory of the case: that the defendant, having agreed to the waiver, is now estopped from challenging it. The Court declines to apply estoppel doctrines, stating that it would "entirely swallow the Act's no-waiver policy." Furthermore, the Court found, since the district court requested the waiver, rather than the defendant, estoppel is not applicable. In addition, the harmless error doctrine does not apply to speedy trial violations.