30 April 2013

Law in Plain English: Boyer v. Louisiana

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

Boyer v. Louisiana

Boyer was indicted for capital murder in Louisiana, where the law requires the state to provide two lawyers to an indigent defendant. Although he had one court-appointed lawyer, funding for the second lawyer was never allocated. Boyer remained in prison for five years, when the state reduced the charges to second-degree murder in order to avoid the second counsel requirement. He was then was tried and convicted of second-degree murder (among other lesser charges) and sentenced to life in prison for the murder. The question before the Court was whether the state’s failure to fund counsel for an indigent defendant for five years as a direct result of the prosecution’s choice to seek the death penalty should be weighed against the state for speedy trial purposes. In a single sentence per curiam (unsigned, anonymous) decision, the Supreme Court dismissed the case as improvidently granted ("DIG"). A DIG is a Court admission that they should not have accepted the case. In a concurrence, Justice Alito reasoned that the record showed the reason for the long delays in Boyer's trial were due to defense requests for continuances, not the lack of funding for a second lawyer. Four justices dissented, arguing that the Court should have ruled on the merits of the case. As a result, the decision of the Louisiana Court of Appeals stands and Boyer's conviction and sentences remain in place.
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