Supreme Court rules in Speedy Trial Act case

[JURIST] The US Supreme Court [official website; JURIST news archive] Thursday ruled [opinion, PDF] in United States v. Tinklenberg [Cornell LII backgrounder] that time for pretrial motions, regardless of whether they actually delay or are expected to delay the beginning of a trial, is excluded from the time in which the accused must be brought to trial. Jason Louis Tinklenberg was convicted of making methamphetamine. His trial began 287 days after his arraignment. The Speedy Trial Act of 1974 (STA) [18 USC § 3161(h)(1)(D) text] requires that accused be brought to trial within 70 days of the arraignment, but time can be excluded for things like pretrial motions. The opinion of the court, written by Justice Stephen Breyer, affirmed the decision [opinion, PDF] of the US Court of Appeals for the Sixth Circuit [official website] to dismiss the charges but disagreed with its reasoning. The Sixth Circuit reasoned that the STA's exemption for "delay resulting from" pretrial motions most reasonably means that the motions actually cause delay or have an expectation to cause delay in the trial. The Supreme Court disagreed with this interpretation as not supported by the context of the phrase and that the courts of appeals have consistently rejected that reasoning in the 37-year history of the STA. Further, the court argued that its interpretation is supported by legislative history and that the Sixth Circuit's standard would make it more difficult to administer, thus hindering the STA's intention to secure fair and efficient trials. However, the court agreed that the indictment should be dismissed because the Sixth Circuit had improperly excluded transportation time in excess of 10 days for weekends and holiday. When the weekends and holidays were added it pushed the time period to trial over the STA's limit. Justice Antonin Scalia, with two others, concurred in the judgment but disagreed with the court's reliance on outside considerations. Scalia argued that the clear meaning of the text itself was that time for pretrial motions should be automatically excluded, regardless of the actual or expected delay. Justice Elena Kagan did not take part in the decision.

The court heard oral arguments [transcript, PDF; JURIST report] in this case in February. Counsel for the government argued that the court should uphold precedent, saying that "[f]or more than 30 years, the courts of appeals had uniformly held that the exclusion applies automatically upon the filing of any motion, regardless of its effect on the trial schedule." Counsel for Tinklenberg argued that the court should use the "ordinary meaning" of the language in the statute, finding that the trial was delayed unlawfully.

 

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