United States v. Bergfeld’s Empirical Analysis
280 F.3d 486 · 2002
Citation profile
19 federal appellate · 2 district · 11 state decisions
How this case has been cited
Cited by 50 later decisions — most recently April 2024 · most notably State v. Garza (2009), Rashad v. Walsh (2002)
19 federal appellate · 2 district · 11 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Barker v. Wingo · Doggett v. United States · Toussie v. United States · Robinson v. Whitley · United States v. Shell
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Doggett v. United States, the Supreme Court clarified how the four factors used to analyze a defendant’s Sixth Amendment speedy trial claim based on a post-indictment delay are weighed, and the burden each party carries. 505 U.S. 647 , 112 S.Ct. 2686 , 120 L.Ed.2d 520 (1992). The threshold inquiry is whether the delay was long enough to trigger a “speedy trial” analysis. Id. at 651-52 , 112 S.Ct. 2686 . Generally, it is accepted that a post-accusation delay approaching one year is sufficient. Id. at 652 n. 1, 112 S.Ct. 2686 . Next, the length of the delay, the reason for the delay, and defendant’s diligence in asserting his or her rights is weighed against the prejudice to the defendant. Id. at 656-57 , 112 S.Ct. 2686 . Depending on how heavily the first three factors weigh for or against the defendant, prejudice is presumed in some cases, relieving the defendant of any burden to show actual prejudice. Id. One lesson from Doggett is that the longer the delay, the greater the presumption of prejudice. Id. at 656 , 112 S.Ct. 2686 .”
2 later decisions quote this exact passage · from the majority“If the government diligently pursues a defendant from indictment to arrest, a speedy trial claim will always fail without a showing of actual prejudice. [Dog-gett, 505 U.S.] at 656, 112 S.Ct. 2686 . On the other hand, if “the Government had intentionally held back in its prosecution ... to gain some impermissible advantage at trial,” that fact weighs heavily against the government. Id. Finally, the Doggett Court explained that: Between diligent prosecution and bad-faith delay, official negligence in bringing an accused to trial occupies the middle ground. While not compelling relief in every case where bad-faith delay would make relief virtually automatic, neither is negligence automatically tolerable simply because the accused cannot demonstrate exactly how it has prejudiced him. Id. at 656-57 , 112 S.Ct. 2686”
1 later decision quote this exact passage · from the majority“The first three factors should be used to determine whether the defendant bears the burden to put forth specific evidence of prejudice (or whether it is presumed); nothing in Doggett endorses the district court’s performing the analysis the other way around, i.e., using the absence of specific evidence of prejudice to reduce the weight of the other three factors.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.