The criminal justice system is far from perfect, but it especially failed one Texas man who spent 32 years in prison waiting for new trial. It seems impossible that this could happen, that no one in 32 years could realize that Jerry Hartfield was still waiting for his day in court. But that is exactly what occurred and it wasn't until, in 2006, a fellow prisoner helped Hartfield, who is developmentally disabled, file motions in numerous courts that there was any movement in Hartfield's case. And even then, he still languished in prison for years until he was finally re-tried in 2015.
Hartfield's story begins way back in 1976, when he was charged and convicted of the murder of 55-year old Eunice Lowe and subsequently sentenced to death. In 1980, Hartfield's conviction was reviewed by the Texas Court of Criminal Appeals which determined that there was "error related to the exclusion of a potential juror." The court then "vacated Hartfield's conviction, and ordered a new trial in its entirety." The State of Texas asked on a motion for re-hearing that the court change the judgment to life in prison or allow the State time to have the Governor commute the sentence. The court denied the State's motion in 1983 and issued a mandate reversing Hartfield's conviction and remanding the case for a new trial.
But something went wrong and despite the fact that his conviction was overturned, for 32 years, "Hartfield remained incarcerated effectively holding a post-indictment, pre-trial status and was under no conviction or sentence."
After many motions and hearings before numerous state and federal courts in Texas, Hartfield ultimately was re-tried for murder. He was once again found guilty and was sentenced to life in prison. Hartfield then appealed his case once again contending, among other things, that his "constitutional right to a speedy trial was violated." This right is guaranteed by both the United States Constitution as well as the Constitution of Texas. The court stated that "[a] speedy trial protects three interests of the defendant: freedom from oppressive pretrial incarceration; mitigation of the anxiety and concern accompanying public accusation; and avoidance of impairment to the accused's defense."
The court determined that the lengthy delay made an inquiry into the speediness of the trial appropriate. The court then considered a four-factor test, called the Barker test. The factors the court considered were: "(1) the length of the delay; (2) the State's reason for the delay; (3) the defendant's assertion of his right to a speedy trial; and (4) prejudice to the defendant because of the length of delay."
The court found that the length of the delay, the State's reason for the delay, and prejudice factors weighed in Hartfield's favor, while the lack of asserting a speedy trial claim for 23 years weighed against him. In balancing the factor's the court found that they weighed against the State and in favor of Hartfield, "due to the unprecedented amount of time Hartfield spent in prison without a conviction or sentence, as well as the serious negligence on the part of the State."
The court then reversed "the trial court's denial of Hartfield's motion to dismiss the State's indictment and render an order dismissing the State's indictment against Hartfield with prejudice." The court stated that "[w]e are deeply mindful that our conclusion today means that a defendant who may be guilty of murder may go free. However, based on the United States Constitution, it is the only possible remedy."
This ruling was handed down in January 2017, however, it is not clear if Hartfield has been released from prison yet.
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