In re: Dennis v. Alabama)Annotate this Case
This case stemmed from a cold-case murder that took place in 1981. An armed robber broke into a gas station where Russell Douglas was working, shot him several times, robbed the station, and fled. Douglas's murderer eluded capture. Then, some 30 years later, forensic scientists retested DNA evidence found at the crime scene and turned up a match to the respondent here, Nathaniel Dennis, who was serving a 600-year sentence in Virginia for an unrelated crime. In 2011, an Alabama grand jury indicted Dennis for the murder of Douglas, and he was transferred to Alabama to stand trial. In 2019, after a series of pretrial delays, Dennis was convicted of murder made capital because it was committed during a burglary. Dennis appealed, arguing that the delay between his indictment and trial violated his right to a speedy trial. The Court of Criminal Appeals agreed, holding that the over-eight-year period between 2011 and 2019 required the trial court to "presume" that the delay prejudiced Dennis's liberty interests -- even though Dennis had not put forward any affirmative evidence of prejudice and likely could not have done so because he was already serving a 600-year sentence in Virginia. The Alabama Supreme Court concluded this was error: the speedy-trial inquiry turns on how much delay has been caused by the government, not the bare amount of time between the indictment and trial. In this case, the portion of the delay caused by government negligence fell well short of the amount needed to justify a presumption of prejudice. Absent that presumption, Dennis' speedy-trial claim failed. The Court reversed the appellate court's judgment and remanded for consideration of the other arguments Dennis raised in his appeal.