United States v. Jeffrey MacDonald
Facts
In May 1970, the defendant, Jeffrey R. MacDonald, was charged with murders of his wife, who was pregnant, and two children by the Army. However, the military charges were dropped later that year, but the Army Criminal Investigation Department had continued with the murder investigations. In June 1972, the Criminal Investigation Department submitted a report to the Justice Department, suggesting that further investigations be done. In 1974, the Justice Department presented the case to a grand jury, and the respondent was charged with three cases of murder in 1975. The defendant, however, appealed the decision of the District Court, citing that his Sixth Amendment right to a speedy trial was violated. The Court of Appeals held that the delay between June 1972 and 1974 violated the Sixth Amendment right to a speedy trial of the respondent.
Issues of the case
Jeffrey R. Macdonald appealed the judgment by raising concerns about the trial and the decisions of the District Court’s ruling. Jeffrey claimed that the right to a speedy trial guaranteed by the Sixth Amendment had been violated. He also claimed that there was an inexcusable delay between the time recommendation for further investigations by the CID and the convening of the grand jury. The respondent also claimed that the delay had violated his entitlement to due process, which is guaranteed by the Fifth Amendment (Dixon, 2019). The legal issues, in this case, are whether the respondent was denied his right to speedy trial mandated in the Sixth Amendment right and whether there was the denial of the due process guaranteed by the Fifth Amendment. Again there is an issue as to whether the delay was unjustifiable, and there was an actual occurrence of prejudice.
Main provisions of the case
The main provisions of this case are the Speedy Trial Clause of the Sixth Amendment and the Due Process Clause of the Fifth Amendment of the United States Constitution. The Speedy Trial Clause states that ‘in all criminal prosecutions, the accused shall enjoy the right to a speedy trial.’ The Speedy Trial Clause shields defendants from unnecessary delays between the time of presentation of charges and the start of the trial. The Due Process Clause provides that ‘no person shall be deprived of life, liberty, or property without the due process of the law.’
Ideally, crime suspects are innocent until proven guilty. Therefore, under the sixth amendment, people facing criminal defendants have the right to a public trial without unnecessary delay. Also, the defendants have a right to a lawyer, the right to an impartial jury, the right to know their accusers as well as the right to the nature of the charges and evidence in the case (Legal Information Institute, 2019). In the case of Jeffrey MacDonald, the murder charges against him dragged from 1970-1975. Besides, the murder charges had initially been dropped, but the Army Criminal Investigation Department continued with investigations.
Effect of the case on law enforcement and the criminal justice system
The Jeffrey MacDonald case has had an enormous impact on law enforcement as well as the criminal justice system. First, the charges against Jeffrey were dropped, but the Army Criminal Investigations Department continued investigating the murders. In line with Dixon (2019), the Army Criminal Investigation Department continued to investigate the killings after the U.S Justice Department asked for further investigations. Therefore, the U.S Justice department can request investigative bodies to investigate further the crimes that seem to have insufficient evidence.
The appeal by Jeffrey MacDonald has an impact on the criminal justice system by interpreting the conditions under which the sixth amendment is applicable. Jeffrey was indicted for three murders in a federal district court five years after the initial murder charges were dropped. However, Jeffrey appealed against the ruling on the grounds of violations of his rights in the sixth amendment. Jeffrey dismissed the indictment, arguing that the delay between the original murder charge in 1970 and the indictment by the grand jury in 1975 violated his right to a speedy trial as per the sixth amendment. However, the appeal by Jeffrey was ruled against because his sixth amendment rights had not been violated. In line with the Legal Information Institute (2019), when the Army Criminal Investigations Department was investigating the murders, Jeffrey MacDonald was not under arrest, not in custody, and not subject to any criminal prosecution. Therefore, the investigations did not hinder MacDonald from carrying on with his daily life activities or subject him to social stigma. Thus, Jeffrey’s sixth amendment rights had not been violated by the investigations by the Army Criminal Investigations Department.
Jeffrey was not denied due process clause rights, as stated in the Fifth Amendment. The Due Process Clause states that no person shall be deprived of life, liberty, or property without the due process of the law’. As stated earlier, the murder charges against Jeffrey had been dropped, but the Army Criminal Investigations Department continued to investigate the murders. During the rime of investigation, Jeffrey was not facing criminal charged, and he was not in custody. Thus, he was not deprived of life, liberty, or property at the time of investigations. Under Federal Habeas Corpus, Jeffrey was at liberty at the time of the investigations, and his fifth amendment rights had not been violated (Primus, 2018). Thus, the case against Jeffrey had upheld his constitutional rights in all the proceedings.
Involvement of the Fourth Amendment
Some people argue that the investigators in the case were fixated on finding evidence against Jeffrey instead of looking for the real killers. At first, the murder charges against Jeffrey were dropped because the incident appeared to be a burglary attack that left three people dead. However, suspicions proliferated that MacDonald had committed the murders and devised a story to look similar to Charles Manson killings, which had occurred six months earlier (Silverglate, 2013). Therefore, when the U.S Justice Department requested the Army Criminal Investigations Department to conduct further investigations, the detectives wanted to prove that Jeffrey was the killer and ignored the testimony by Jeffrey. According to Silverglate (2013), the prosecutors at the Department of Justice saw Jeffrey as an easy target and focused on getting him indicted.
The case against Jeffrey, however, did not violate the fourth amendment. The fourth amendment protects people from unlawful searches and seizures. Also, evidence acquired in violation of the fourth amendment cannot be used to prove guilt in a court of law. The U.S Department of Justice had authorized the investigations against Jeffrey. Therefore, all searches and seizures during the investigations were legal.
My Thoughts about the case
I think Jeffrey faced a fair trial, although the case dragged for years. In his initial appeal, Jeffrey argued that his sixth amendment right to a speedy trial had been violated. However, the court rules against the petition because Jeffrey was not facing any criminal charges during the time of the investigation. I think the U.S Department of Justice was fair to refrain from filing criminal charges against Jeffrey before the investigation was complete. In so doing, the department of justice upheld the sixth amendment by giving Jeffrey a speedy trial after years of investigation. Although some people argue that Jeffrey was innocent and the Justice Department framed him for the murders, I think Jeffrey faced a fair trial, and the final verdict was based on irrefutable evidence.
References
Dixon, P. (2019, February 19). The Dr. Jeffrey MacDonald Habeas Case and Actual Innocence. Retrieved October 21, 2019, from North Carolina Criminal Law: https://nccriminallaw.sog.unc.edu/the-dr-jeffrey-macdonald-habeas-case-and-actual-innocence/
Legal Information Institute . (2019). UNITED STATES, Petitioner v. Jeffrey R. MacDONALD. Retrieved October 21, 2019, from Legal Information Institute: https://www.law.cornell.edu/supremecourt/text/456/1
Legal Information Institute. (2019). Sixth Amendment . Retrieved October 21, 2019, from Legal Information Institute: https://www.law.cornell.edu/constitution/sixth_amendment
Primus, E. B. (2018). Litigating Federal Habeas Corpus Cases: One Equitable Gateway at a Time.
Silverglate, H. (2013, May). Reflections on the Jeffrey MacDonald Case. Retrieved October 21, 2019, from National Association of Criminal Defense Lawyers: https://www.nacdl.org/Article/May2013-ReflectionsontheJeffreyMacDonald