United States v. Hopkins, No. 23-1836 (3d Cir. 2024)
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The case involves the United States government's appeal against the District Court's dismissal of one of two counts in an indictment against Reginald Hopkins. Hopkins was initially arrested on state firearms charges, and while awaiting his state preliminary hearing, a federal grand jury indicted him on charges of distributing cocaine base and being a felon in possession of firearms and ammunition. The state charges were subsequently withdrawn. Hopkins moved to dismiss the federal indictment, invoking a so-called "ruse exception" to the Speedy Trial Act (STA), arguing that his rights under the Act had been violated because he had been federally indicted over four months after his arrest by state authorities and because he had not been brought to trial within 70 days of that state arrest.
The District Court held two evidentiary hearings and eventually dismissed one count of the indictment, the felon-in-possession charge, based on the ruse exception. The government appealed this decision, arguing that the STA contains no such ruse exception.
The United States Court of Appeals for the Third Circuit agreed with the government, concluding that a ruse exception premised on a state arrest is inconsistent with the text of the STA and that there are sound policy reasons for declining to adopt a ruse exception. The Court reversed the order of the District Court and reinstated the dismissed count of the indictment.
The court issued a subsequent related opinion or order on August 2, 2024.
The court issued a subsequent related opinion or order on August 2, 2024.
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