United States District Court, D. Maryland
L. HOLLANDER UNITED STATES DISTRICT JUDGE
Alexander Jiggetts filed this civil rights complaint on
November 13, 2018, together with a motion to proceed in forma
pauperis (ECF 2), which shall be granted. In his complaint,
Jiggetts challenges the constitutionality of plea bargaining
and the denial of his Sixth Amendment right to a speedy trial
in the case of State v. Jiggetts, No. 816180013
(Balt. City Cir. Ct. 2016).
noted, Jiggetts filed his complaint in forma pauperis
pursuant to 28 U.S.C. § 1915(a)(1), which permits an
indigent litigant to commence an action in this court without
prepaying the filing fee. To guard against possible abuses of
this privilege, the statute requires dismissal of any claim
that is frivolous malicious, or fails to state a claim on
which relief may be granted. 28 U.S.C. §
1915(e)(2)(B)(i) and (ii).
court is mindful, however, of its obligation to liberally
construe pleadings of self-represented litigants, such as the
instant complaint. See Erickson v. Pardus, 551 U.S.
89, 94 (2007). In evaluating such a complaint, the
well-pleaded factual allegations are assumed to be true.
Id. at 93 (citing Bell Atlantic Corp.
v. Twombly, 550 U.S. 544, 555-56 (2007)).
Nonetheless, liberal construction does not mean that this
court can ignore a clear failure in the pleading to allege
facts that set forth a cognizable claim. See Weller v.
Dep't of Soc. Servs., 901 F.2d 387 (4th Cir. 1990);
see also Beaudett v. City of Hampton, 775 F.2d 1274,
1278 (4th Cir. 1985) (stating a district court may not
“conjure up questions never squarely
presented.”). In making this determination, A[t]he
district court need not look beyond the complaint's
allegations . . . . It must hold the pro se complaint to less
stringent standards than pleadings drafted by attorneys and
must read the complaint liberally.@ White v. White,
886 F.2d 721, 722-723 (4th Cir. 1989).
claims that it was unconstitutional for the State to
negotiate a plea deal with a criminal defendant. Notably, he
does not claim that his guilty plea was involuntary or
otherwise invalid. Where a criminal defendant “clearly
and unequivocally declared to the trial judge that he wanted
to represent himself and did not want counsel, ” it is
a denial of that defendant's constitutional right to
conduct his own defense to impost counsel upon him.
Faretta v. California, 422 U.S. 806, 835 (1975).
the Supreme Court has observed:
A valid guilty plea also renders irrelevant-and thereby
prevents the defendant from appealing-the constitutionality
of case-related government conduct that takes place before
the plea is entered. See, e.g., Haring [v.
Prosise, 462 U.S. 306, 320, (1983)] (holding a valid
guilty plea “results in the defendant's loss of any
meaningful opportunity he might otherwise have had to
challenge the admissibility of evidence obtained in violation
of the Fourth Amendment”). Neither can the defendant
later complain that the indicting grand jury was
unconstitutionally selected. Tollett [v.
Henderson, 411 U.S. 258, 266 (1973)].
Class v. United States, U.S., 138 S.Ct. 798, 805
guilty plea relinquishes rights related to the trial such as
“the privilege against compulsory self-incrimination,
the jury trial right, and the right to confront accusers,
[but] they do McCarthy v. United States, 394 U.S.
459, 466 (1969); quoting Mitchell v. United States,
526 U.S. 314, 324 (1999)).
asserts that he was denied his Sixth Amendment right to a
speedy trial. ECF 1. That right, like the right to a jury
trial or the right to confront accusers, exists within the
confines of the trial and is waived by a guilty plea. See
Barker v. Wingo, 407 U.S. 514, 521 (1972)
(“deprivation of the right to speedy trial does not per
se prejudice the accused's ability to defend
himself.”) Additionally, Jiggetts' trial was
delayed because he was found not competent to stand trial and
was involuntarily committed for purposes of treating an
underlying mental health condition, so that he would later be
able to understand the proceedings against him and assist in
his own defense. See Jiggetts v. State of Maryland.,
Civil Action JFM-15-2676 (D. Md. 2015) at ECF 2 (Memorandum
dismissing case for failure to exhaust habeas petition).
Jiggetts' case, there is no evidence of “[a]
deliberate attempt to delay the trial in order to hamper the
defense” which “should be weighted heavily
against the government.” Barker, 407 U.S. at
531. Rather, Jiggetts' lack of competence to stand trial
represents “a valid reason” which “should
serve to justify appropriate delay.” Id.;
see also State v. Kanneh, 403 Md. 678, 690 (Md.
2008) (finding delay in trial due to unavailability of DNA
evidence a “neutral” postponement). To insist
that a criminal defendant, regardless of his competency, must
be tried within a strict window of time is simply not within
the purview of the constitutional guarantee of a speedy trial
and would not serve to protect the accused or guarantee a
fair trial. The resulting inequities against the accused in
such a circumstance would almost invariably result in an
invalid trial or conviction. See Dusky v. United
States, 362 U.S. 402, 403 (1960) (finding trial record
insufficient to support a finding of competency and ordering
a new trial).
the complaint must be dismissed for failure to state a claim.
A separate Order follows.