United States v. Saguto, No. 18-1276 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's sentence imposed after he conditionally pleaded guilty to escaping from prison and conspiracy to escape. The court held, after weighing all the relevant factors, that the time lapse between defendant's indictment and guilty plea did not violate his Sixth Amendment right to a speedy trial. In this case, while the 22 month delay was presumptively prejudicial, the responsibility for the delay and the prejudice factors weighed against defendant.
The court declined to address defendant's ineffective assistance of counsel claim on direct review. Finally, the court held that the district court did not abuse its discretion in sentencing defendant to 36 months in prison and expressly weighed all the 18 U.S.C. 3553(a) sentencing factors. Therefore, defendant's above-Guidelines sentence was not substantively unreasonable.
Court Description: Smith, Author, with Colloton and Erickson, Circuit Judges] Criminal case - Criminal law and sentencing. With respect to defendant's speedy trial claim, while the 22-month delay between his indictment and guilty plea was presumptively prejudicial, the other relevant factors, such as prejudice and responsibility for the delay, did not favor defendant, and the district court did not err in finding defendant's Sixth Amendment rights were not violated by the delay; claim that counsel was ineffective in failing to raise the issue would not be considered on direct appeal; defendant's above-guidelines range sentence was not substantively unreasonable.
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