United States v. Blount, No. 22-2470 (7th Cir. 2024)
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In this case, the United States Court of Appeals for the Seventh Circuit considered an appeal by Linnel Blount, Jr., who was convicted on drug and gun charges in 2019 and sentenced to 63 months in prison. Blount's jury trial was initially set for February 2020 but was postponed to March 2020 at his request. However, due to the COVID-19 pandemic, a series of court orders suspended criminal jury trials from March 2020 through April 2021. The district judge deferred Blount's trial further during this period, citing health and safety considerations. Blount eventually waived his jury trial and agreed to a bench trial, which commenced in July 2021.
On appeal, Blount argued that his indictment should have been dismissed under the Speedy Trial Act because the delay of his trial was based on the general pandemic-related court orders rather than individualized, case-specific circumstances. However, the court of appeals found that Blount's lawyer did not make a formal motion to dismiss the indictment, which is necessary under the Speedy Trial Act. Moreover, the court determined that the district judge was not required to interpret Blount's pro se filings as implicit motions to dismiss.
More broadly, the court held that the Speedy Trial Act does not require judges to reiterate considerations that have already been established by the court as an institution. It concluded that the delay of criminal jury trials during the COVID-19 pandemic was justified by societal, not personal, considerations, and that such delays were permissible under the Speedy Trial Act. The court affirmed Blount's conviction and sentence.
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