Speedy trials and false confessions
Jonathan Edward Boyer v. Louisiana
In brief
The justices ended Supreme Court review without deciding whether Louisiana should bear responsibility for the funding-related trial delay.
- Where it stands
- Decided
Decided 5-4 · April 29, 2013 · Per curiam
- What it’s about
- The case asked whether Louisiana’s failure to pay for a lawyer for a defendant who could not afford one should count against the state when deciding whether his right to a speedy trial was violated.
- Who it affects
- Boyer received no Supreme Court answer on whether delays tied to Louisiana’s failure to pay for his lawyer should count against the state in his speedy-trial claim.
Summary: written with AI from the case record.
What it's about
The Supreme Court ended its review without deciding that issue, dismissing its review as improvidently granted (ending review after agreeing to hear the case).
Justice Sotomayor wrote that Boyer spent more than seven years in jail between his arrest and trial.
The case concerned the Constitution’s right to a speedy trial.
Question presented
1. Should a state's failure to fund counsel for an indigent defendant for five years be weighed against the state for speedy trial purposes? 2. Is a defendant's due process right to present a complete defense, to compulsory process, and to confront the witnesses against him violated when relevant and reliable expert testimony as to the psychology of interrogations and false confessions is excluded at trial?
What the Court decided
Holding
The writ of certiorari is dismissed as improvidently granted.
- Result
- Dismissed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Majority · 3joined the Court's opinion
- Scalia
- Kennedy
- Roberts
From the opinions
“Such a delay should weigh against the State.”
What's next
Supreme Court review is over, and the Louisiana appeals court’s rejection of Boyer’s speedy-trial claim remains in place. The Supreme Court gave no further instructions.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Boyer
Opinion added: Boyer
More questions
- What did the Louisiana appeals court find about the delay?
- It found that most of the delay came from the state’s failure to pay for Boyer’s defense, but treated the delay as outside the state’s control.
- What did Justice Sotomayor say should happen?
- She said the delay should count against Louisiana when judging Boyer’s speedy-trial claim.
- Why did Justice Alito support ending review?
- He said the record did not support the premise that Louisiana’s failure to pay for Boyer’s lawyers caused most of the delay.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.