United States v. Johnson, No. 19-1610 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit held that the Speedy Trial Act does not permit exclusion of days caused by the court's own scheduling conflicts resulting from a crowded docket. The court explained that this constitutes general congestion under the Act and is not a legitimate ground upon which to exclude days under the Act. In this case, because the district court's reason for delay was not excludable under the act, the court will permit the district court to determine in the first instance whether to dismiss the indictment with or without prejudice by applying the factors set forth in 18 U.S.C. 3162(a)(2). The court also weighed the Barker factors and affirmed the district court's denial of defendant's Sixth Amendment claim. The court assessed the prejudice to defendant and concluded that her anxiety alone was insufficient to demonstrate prejudice.
Court Description: [Smith, Author, with Loken and Gruender, Circuit Judges] Criminal case - Criminal law. The district court erred in continuing defendant's trial because of the scheduling conflicts resulting from a crowded docket; as a result, the length of that delay is not excludable for Speedy Trial Act purposes, and a Speedy Trial Act violation occurred; the appropriate remedy in this case is to remand the matter to permit the district court to determine in the first instance whether to dismiss the indictment with or without prejudice by applying the factors set forth in 18 U.S.C. Sec. 3162(a)(2); the delay did not violate defendant's Sixth Amendment speedy trial rights, and the district court did not err in denying defendant's Sixth Amendment claim; Judge Loken, concurring.
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