United States v. Espinal, No. 19-1341 (8th Cir. 2020)
Annotate this Case
The Eighth Circuit affirmed defendant's conviction for illegal reentry into the United States. The court declined to reach the issue of whether there is a "ruse exception" to the Speedy Trial Act because, even assuming that the exception exists, the facts in this case do not show that any such ruse occurred. Furthermore, the district court did not abuse its discretion in declining to hold a hearing on the motion to dismiss the indictment before denying it.
The court also held that, even assuming without deciding, that there were fundamental procedural errors in the underlying removal proceedings, defendant has not met his burden in demonstrating actual prejudice—that but for those errors, there was a reasonable likelihood he would not have been deported. Finally, the court held that the district court did not abuse its discretion in disposing of this issue without a hearing
Court Description: [Shepherd, Author, with Colloton and Erickson, Circuit Judges] Criminal case - Criminal law. Speedy Trial Act claim rejected; in this prosecution for illegal reentry, defendant attacked the underlying removal order; even assuming that there were fundamental procedural errors in the defendant's underlying removal proceedings, he failed to show the required prejudice, that is that but for the errors there was a reasonable likelihood that he would not have been deported; the district court did not abuse its discretion in resolving the claim without a hearing.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.