United States v. Torres, No. 21-50006 (9th Cir. 2021)
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In light of the COVID-19 pandemic, the Ninth Circuit is asked to determine the limits that federal law and the Constitution place on holding an accused person in detention solely for the purpose of awaiting trial. In this case, defendant appealed the district court's denial of his motion for release from pretrial detention. His trial has been delayed and his detention prolonged as a result of the district court's findings that the "ends of justice" served by avoiding the serious public health risks presented by holding a trial during the COVID-19 pandemic outweighed his right to a speedy trial.
The panel held that defendant's pretrial detention is consistent with the Speedy Trial Act. First, the panel concluded that because the plain text of the Act, 18 U.S.C. 3161(h)(7), requires consideration of the best interest of the defendant in a speedy trial, an ends-of-justice analysis will necessarily include consideration of whether the defendant is detained. Second, the panel concluded that section 3164(b) unambiguously provides that time properly excluded under section 3161(h) is properly excluded from section 3164. The panel explained that, because the record suggests that the district court considered defendant's detention in granting the ends-of-justice continuances here, his pretrial detention was properly tolled under the Speedy Trial Act. The panel further concluded that due process does not yet require defendant's release, but observed that the length of defendant's pretrial detention is likely approaching the outer bounds of due process.
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