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New York v. Hill

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New York v. Hill
Seal of the United States Supreme Court.svg
Argued November 2, 1999
Decided January 11, 2000
Full case nameNew York v. Michael Hill
Citations528 U.S. 110 ( more )
120 S. Ct. 659; 145 L. Ed. 2d 560; 2000 U.S. LEXIS 262
Case history
PriorMotion to dismiss indictment denied, Monroe County Court, New York; conviction affirmed, 244 A.D.2d 927, 668 N.Y.S.2d 126 (N.Y. App. Div. 1997); reversed and indictment dismissed, 92 N.Y.2d 406, 704 N.E.2d 542 (N.Y. 1998); cert. granted, 526 U.S. 1111 (1999)
Holding
A defense counsel’s agreement to a trial date outside the 180-day period provided by Article III of the Interstate Agreement on Detainers waives the defendant’s right to seek dismissal on the ground that the trial did not occur within that period.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
David Souter  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Case opinion
MajorityScalia, joined by Rehnquist, Stevens, O'Connor, Kennedy, Souter, Thomas, Ginsburg, Breyer
Laws applied
Interstate Agreement on Detainers

New York v. Hill, 528 U.S. 110 (2000), was a United States Supreme Court case in which the Court unanimously decided that scheduling of a trial date outside the 180-day period of Article III of the Interstate Agreement on Detainers Act (IAD) by a defendant's counsel waived the defendant's right to dismissal on the ground that the trial did not occur within that period. The court clarified that decisions about scheduling are among those entrusted to counsel and do not require a defendant's personal consent. [1] [2] [3] The trial court declared that the defense counsel's agreement to hold the trial after that period waivered Hill's IAD rights. [2] [1]

Contents

Background

Michael Hill, an Ohio state prisoner, was the subject of a detainer lodged by New York authorities on pending murder and robbery charges. Hill invoked Article III of the IAD, requesting resolution of the detainer, and was transferred to New York for trial. [2] His counsel filed several pretrial motions, tolling the 180-day clock during their pendency.

On January 9, 1995, during a scheduling hearing, the prosecutor proposed May 1 as a trial date. The trial judge asked defense counsel whether that date was acceptable, and counsel responded, "That will be fine, Your Honor". The court set the trial for May 1, which fell beyond the 180-day period. [4]

Before trial, Hill moved to dismiss the indictment on the ground that the IAD's time limit had expired. The trial court denied the motion, holding that defense counsel's explicit agreement to the trial date constituted a waiver of Hill's IAD rights. Hill was subsequently convicted of second-degree murder and first-degree robbery. The Appellate Division of the New York Supreme Court affirmed the conviction, but the New York Court of Appeals reversed, ruling that defense counsel's agreement did not waive Hill's speedy-trial rights under the IAD and ordering dismissal of the indictment. The Supreme Court granted certiorari.

Opinion of the court

Justice Scalia delivered the unanimous opinion reversing the New York Court of Appeals. The Supreme Court held that defense counsel's agreement to a trial date outside the IAD's statutory time frame constituted a waiver of the defendant’s right to dismissal on speedy-trial grounds, stating, "[w]hat suffices for waiver depends on the nature of the right at issue". While certain fundamental rights, such as the right to counsel or the right to enter a not guilty plea, require a defendant's personal waiver, many procedural rights may be waived by counsel acting on the defendant's behalf, including decisions about scheduling. [1]

Accordingly, the Court reversed the judgment of the New York Court of Appeals and reinstated Hill's conviction. [1]

References

  1. 1 2 3 4 James J. Tomkovicz, The Right to the Assistance of Counsel: A Reference Guide (2002), p. 77-78.
  2. 1 2 3 "New York v. Hill". Oyez. Retrieved 2025-04-10.
  3. "New York v. Hill". LII / Legal Information Institute. Retrieved 2025-04-10.
  4. "New York v. Hill Case Brief Summary – Facts, Issue, Holding & Reasoning – Studicata". www.studicata.com. Retrieved 2025-09-12.
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