United States v. Macias Lozano, No. 19-4082 (4th Cir. 2020)Annotate this Case
On appeal, defendant contends that the delay of over six years between the date of his federal charge and the date of his guilty plea violated his Sixth Amendment right to a speedy trial. Defendant also contends that his sentence was procedurally unreasonable.
The Fourth Circuit held that defendant's speedy trial argument is foreclosed by his guilty plea and, in any event, failed on the merits. In this case, defendant did not know of the pending federal charge until he was arrested and thus he did not experience oppressive pretrial incarceration or anxiety during the delay. Nor does defendant assert that the delay impaired his ability to prepare a defense. Furthermore, defendant failed to show prejudice. The court also held that defendant's sentence is procedurally reasonable where the district court acted within its discretion when it heard defendant's arguments and varied downward, albeit not as far as defendant would have liked. Accordingly, the court affirmed the district court's judgment.