United States v. Seal, No. 10-4192 (10th Cir. 2011)Annotate this Case
Defendant-Appellant Autumn Seals sought reversal of his conviction on the grounds that he was denied a speedy trial. In this appeal, Defendant argued that the district court abused its discretion in granting a continuance without counting the elapsed time against the Speedy Trial Act clock. He argued that a new charge against him and the introduction of an alibi witness didn’t materially change the complexion of the case and didn’t justify a long a delay. And because the district court’s findings were insufficient to trigger an "ends-of-justice" delay, the Speedy Trial clock continued to run and expired long before his eventual trial. Upon review, the Tenth Circuit concluded that Defendant did not adequately preserve this issue for appeal. As such, the Tenth Circuit affirmed the district court's decision and Defendant's conviction.