Klopfer v. North Carolina facts for kids
Quick facts for kids Klopfer v. North Carolina |
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| Argued December 8, 1966 Decided March 13, 1967 |
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| Full case name | Peter H. Klopfer, Petitioner v. State of North Carolina. |
| Citations | 386 U.S. 213 (more)
87 S. Ct. 988; 18 L. Ed. 2d 1
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| Prior history | State v. Klopfer, 266 N.C. 349, 145 S.E.2d 909 (1966); cert. granted, 384 U.S. 959 (1966). |
| Holding | |
| By indefinitely postponing prosecution, the State denied petitioner the right to a speedy trial guaranteed by the Sixth Amendment to the United States Constitution | |
| Court membership | |
| Case opinions | |
| Majority | Warren, joined by Black, Douglas, Clark, Brennan, White, Fortas |
| Concurrence | Harlan |
| Concurrence | Stewart |
| Laws applied | |
| U.S. Const. amends. VI, XIV | |
Klopfer v. North Carolina was an important case decided by the U.S. Supreme Court in 1967. This case was about a person's right to a speedy trial. The Sixth Amendment in the Bill of Rights says that everyone accused of a crime has the right to a quick trial.
In this case, a man named Peter Klopfer was on trial, but the jury could not decide if he was guilty or not. Instead of ending the case, the prosecutor used a special rule in North Carolina that left the charges against Klopfer open, possibly forever. Klopfer argued that this went against his right to a speedy trial. The Supreme Court agreed with him. This decision was very important because it meant that the right to a speedy trial, found in the Sixth Amendment, also applies to state courts, not just federal courts. This idea is called "incorporation."
Contents
What Happened Before the Case?
On January 3, 1964, Peter Klopfer, a professor and civil rights activist, was protesting against segregation in a restaurant. He was accused of entering private property in Chapel Hill and refusing to leave.
In February 1964, a grand jury in Orange County charged him with criminal trespass. Klopfer said he was not guilty. His trial happened in March, but the jury could not agree on a verdict. This meant the trial ended without a decision.
The Unusual North Carolina Rule
After the trial, the prosecutor asked the court to use a special rule called "nolle prosequi with leave." This rule was only used in North Carolina at the time. When a judge allowed this, it meant the charges against Klopfer were not completely dropped.
Normally, if a prosecutor stops a case, they need a judge's permission to start it again. But with "nolle prosequi with leave," the prosecutor could restart Klopfer's case at any time without asking the judge again. Also, there was no time limit for how long they could wait. This meant the charges could hang over Klopfer's head forever.
Klopfer's lawyer argued that this rule was unfair. He said it violated Klopfer's right to a speedy trial because the charges were never truly gone. This made it hard for Klopfer to travel or do his work as a professor.
North Carolina's View
Klopfer took his argument to the North Carolina Supreme Court. But that court said the right to a speedy trial only mattered if a trial was actually happening. They believed Klopfer was trying to force the state to prosecute him, which they saw as interfering with the prosecutor's job. The North Carolina court said this special rule was part of "customary procedure" and could not be reviewed. So, they upheld the lower court's decision.
The Supreme Court's Decision
The U.S. Supreme Court decided to hear Klopfer's case. One main reason was to decide if the Sixth Amendment's right to a speedy trial should apply to state courts, which the North Carolina court had disagreed with.
Reviewing the Rule
Chief Justice Earl Warren wrote the Supreme Court's opinion. He looked closely at the "nolle prosequi with leave" rule. He called it a "very unusual" and "extraordinary" way to handle a criminal case. The Court found that this rule was not based on any North Carolina law or old English legal traditions that North Carolina followed.
The Court noted that Klopfer was charged quickly, but the special rule was used more than a year and a half later. The prosecutor did not give any good reason for using it. Klopfer, who was a zoology professor at Duke University, told the Court that having these charges hanging over him made it hard for him to work and travel freely.
The History of Speedy Trial Rights
Chief Justice Warren's decision went into great detail about the history of the right to a speedy trial. He showed that this right goes back a very long time in English common law, even to documents like the Magna Carta in 1215.
He explained that the people who founded the United States knew a lot about English law. They wanted Americans to have these same important rights. The right to a speedy trial was put into the U.S. Constitution and many early state constitutions. By 1967, every state in the U.S. had some form of this right. Chief Justice Warren called it "one of the most basic rights" protected by the Constitution.
Applying Rights to the States
The Supreme Court also decided that the Sixth Amendment's guarantee of a speedy trial applies to the states. Building on earlier important cases, the Court said that the right to a speedy trial is just as important as any other right in the Sixth Amendment. Because of this, it applies to the states through the Fourteenth Amendment. This meant the North Carolina Supreme Court's decision was overturned.
What Changed After the Decision?
The Klopfer v. North Carolina case was cited by the Supreme Court many times later. It was a key part of how the Bill of Rights protections were applied to cases in state courts.
Later Cases
- In 1969, the case of Smith v. Hooey, 393 U.S. 374 (1969) used Klopfer to say that defendants must get a speedy trial even if they are held in a different state from where they were charged.
- In 1970, Dickey v. Florida, 398 U.S. 30 (1970) said the same rule applied if a defendant was held in a different part of the same state.
- However, the Supreme Court did not fully explain what "speedy" meant until the 1972 case of Barker v. Wingo, 407 U.S. 514 (1972). This case created a four-part test to decide if a delay in a trial was too long or harmful.
Changes in North Carolina Law
Because of the Klopfer decision, North Carolina changed its laws in 1973. The "nolle prosequi with leave" rule was removed. Now, prosecutors can drop charges without the possibility of bringing them back indefinitely. However, state law still allows prosecutors to temporarily stop charges if the delay is caused by the defendant, for example, if they do not show up for court.
See also
- List of United States Supreme Court cases, volume 386
- List of United States Supreme Court cases
