Is there a Sixth Amendment right to a speedy trial in supervised release revocation proceedings?

MultiRegion, United States of America

The following excerpt is from United States v. Gavilanes-Ocaranza, 772 F.3d 624 (9th Cir. 2014):

There is no Sixth Amendment right to a speedy trial in supervised release revocation proceedings, because those proceedings are not part of a criminal prosecution and thus the full panoply of rights due a defendant in such a proceeding does not apply. United States v. Hall, 419 F.3d 980, 985 (9th Cir.2005) (internal quotation marks omitted). A defendant does have a right to a reasonably prompt hearing on revocation of supervised release, but that right is rooted in the Fifth Amendment's Due Process Clause, not in the Sixth Amendment's Speedy Trial Clause. United States v. Santana, 526 F.3d 1257, 1259 (9th Cir.2008).

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