United States v. Adams, No. 19-1811 (3d Cir. 2022)
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Adams was not tried until 2017, nearly two years after his arraignment on firearms charges. Rejecting his motions to dismiss on Speedy Trial Act grounds, the district court described “numerous continuances [and] unnecessary motions,” caused by Adams’s “obstreperous behavior.” At one point, because of Adams’s demands, the judge canceled a scheduled trial date and did not set a particular date for that future hearing or for trial, without citing 18 U.S.C. 3161(h)(7)(A), which allows district courts to pause the speedy trial clock by entering a continuance, or state that this continuance would serve the “ends of justice.” Adams also argued that motions in limine filed by the government did not qualify for the Act’s exclusion of “delay resulting from any pretrial motion” under 3161(h)(1)(D), and that his motion for discovery did not toll the clock from its filing through its official disposition.
The Third Circuit affirmed his convictions, concluding those periods of delay were excluded, The district court did not plainly err in failing to instruct the jury on the “knowledge-of-status” element under “Rehaif.” The record makes clear that Adams devised his straw-purchaser scheme precisely because he knew he was a felon who could not lawfully possess firearms.
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