United States v. Sutton, No. 16-5587 (6th Cir. 2017)
Annotate this CaseIn 2005, Sutton committed four armed bank robberies in quick succession in Kentucky and Ohio. He agreed to plead guilty to the Kentucky charges in the Southern District of Ohio. Sutton never formally entered a guilty plea to the Kentucky charges but was sentenced as if he had. Five years later, Sutton moved to vacate (28 U.S.C. 2255), challenging his conviction on the Kentucky charges. The Southern District of Ohio vacated the conviction and transferred the case to the Eastern District of Kentucky, where Sutton was arraigned and entered a not guilty plea, 11 years after he was indicted. He moved to dismiss, alleging that violations of the Speedy Trial Act, 18 U.S.C. 3161, and the Sixth Amendment. The court denied the motion. Sutton entered a conditional plea and was sentenced to 25 years to run consecutively to the Ohio sentence. The Sixth Circuit affirmed. The speedy trial analysis is “necessarily relative. It is consistent with delays and depends upon circumstances.” Even if all four “Barker factors” are satisfied, a court is not required to conclude that a defendant’s speedy trial right was violated. The unique facts of this case demonstrate why such flexibility is necessary. Although the Ohio court and the government were at fault, their collective behavior was consistent with Sutton’s intention to plead guilty.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.