People v. Blakley, 34 N.Y.2d 311 (1974)

A prosecutor cannot condition a plea bargain on the defendant’s waiver of their right to a speedy trial, as this is inherently coercive, and an unreasonable delay in bringing a defendant to trial violates their right to a speedy trial under the Sixth Amendment and relevant state statutes.

Summary

George Blakley was indicted for assault and firearm possession in 1966, but his trial did not begin until 1969. During the trial, the prosecutor offered a reduced plea deal on the condition that Blakley withdraw his motion to dismiss the indictment for lack of speedy trial. Blakley accepted, but appealed, arguing his right to a speedy trial was violated. The New York Court of Appeals held that conditioning a plea bargain on waiving speedy trial rights is inherently coercive and violates public policy. Furthermore, the Court found Blakley’s right to a speedy trial was indeed violated due to the significant delay and lack of good cause shown by the prosecution.

Facts

George Blakley, Jr. was arrested on November 15, 1965, and indicted on January 11, 1966, for assault and possession of a loaded firearm. The charges stemmed from an incident on November 14, 1965, where Blakley allegedly shot and wounded two individuals. The case experienced significant delays and did not proceed to trial until February 4, 1969, over three years after the indictment. During the trial, after the testimony of the victims, Blakley offered to plead guilty to two counts of assault in the second degree.

Procedural History

Blakley was indicted in January 1966. In February 1968, Blakley moved to dismiss the indictment for failure to prosecute. The County Court denied the motion. Blakley then pleaded guilty during trial after a plea bargain conditioned on withdrawing the speedy trial motion. He appealed the judgment of conviction, arguing his speedy trial rights were violated. The New York Court of Appeals reversed the order and dismissed the indictment.

Issue(s)

1. Whether a prosecutor may condition a plea offer on the defendant withdrawing a speedy trial claim.
2. Whether the delay between indictment and trial violated the defendant’s right to a speedy trial.

Holding

1. No, because conditioning a plea bargain on waiving a speedy trial claim is inherently coercive and against public policy.
2. Yes, because the prosecution failed to show good cause for the significant delay in bringing the defendant to trial.

Court’s Reasoning

The Court reasoned that the right to a speedy trial is not solely for the defendant’s benefit, but also serves a societal interest. Conditioning a plea bargain on waiving this right allows prosecutors to submerge speedy trial challenges, potentially leading innocent defendants to plead guilty to avoid an unfair, delayed trial. The Court emphasized that “the criminal justice system should scrupulously avoid the possibility that a plea of guilty may be tainted by unfairness.” The Court also found the purported waiver of the speedy trial claim ineffectual due to the coercive nature of the plea bargain.

Regarding the speedy trial claim, the Court applied Section 668 of the Code of Criminal Procedure, which required the prosecution to show “good cause” for delays. The Court also considered the factors outlined in Barker v. Wingo: the length of the delay, the reasons for the delay, the defendant’s assertion of the right, and the prejudice to the defendant. The Court found the 34-month delay between indictment and the defendant’s change of attorney was excessive. While calendar congestion and a missing witness were cited as reasons for the delay, the Court found them insufficient. The Court noted the witness (Young) was available for a significant period and the District Attorney’s office did not diligently attempt to secure his presence. Ultimately, the Court concluded that the length of the delay and the defendant’s assertion of his right outweighed the reasons offered by the prosecution, thus violating Blakley’s right to a speedy trial.