Delays in criminal sentencing
Betterman v. Montana
In brief
The Supreme Court said the Sixth Amendment speedy-trial right ends at a guilty plea or guilty verdict and agreed with Montana’s court.
- Where it stands
- Decided
Decided 8-0 · May 19, 2016 · Opinion by Justice Thomas
- What it’s about
- Brandon Betterman argued that a 14-month wait for sentencing after his guilty plea violated his right to a speedy trial.
- Who it affects
- Defendants who plead guilty or are found guilty at trial cannot use the Sixth Amendment’s speedy-trial guarantee to challenge sentencing delays; the Court left possible due-process claims undecided.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the Sixth Amendment’s protection does not cover delays after a guilty plea or guilty verdict and agreed with Montana’s court (affirmed); it did not decide whether the delay violated due process.
Betterman’s appeal raised only the Sixth Amendment issue; a due-process challenge was not before the Court.
Question presented
Is it a violation of the Sixth Amendment right to a speedy trial to postpone sentencing for fourteen months after a guilty plea has been issued?
What the Court decided
Holding
The Sixth Amendment’s speedy trial guarantee does not apply once a defendant has been found guilty at trial or has pleaded guilty to criminal charges. 378 Mont. 182, 342 P. 3d 971, affirmed.
- Result
- Affirmed
The vote
What's next
The Supreme Court left Montana’s ruling in place. It did not decide whether an undue sentencing delay could violate due-process protections.
Documents
Opinions
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
Opinion added: Betterman
More questions
- Did the Court decide what test applies to due-process claims about sentencing delays?
- No. Justice Sonia Sotomayor suggested using factors from an earlier speedy-trial case, but the Court left the question open.
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.