Facts
-
Federal prosecutors charged Thomas J. Henderson, Scott O. Thornton, and Ruth Freedman with offenses related to controlled substances in the District of Nevada.
-
The Speedy Trial Act’s 70-day period began running on September 3, 1980.
-
Trial began on November 1, 1982, after delays that included:
- A defense motion to suppress evidence, a hearing on that motion, and post-hearing submissions.
- A defense motion for reconsideration of the suppression ruling.
- A defense motion to dismiss the indictment for an asserted Speedy Trial Act violation.
-
The district court denied dismissal, treated substantial motion-related time as excludable under the Act, and the defendants were convicted.
-
The Ninth Circuit affirmed, rejecting the argument that only “reasonably necessary” delays are excludable under 18 U.S.C. § 3161(h)(1)(F).
Issues
- Whether 18 U.S.C. § 3161(h)(1)(F) excludes all time between the filing of a pretrial motion and the conclusion of the hearing on that motion, or only time that is “reasonably necessary.”
- Whether § 3161(h)(1)(F) excludes time after a motion hearing while the district court awaits additional filings needed to decide the motion.
Decision
- The Supreme Court affirmed the judgment.
- The Court held that § 3161(h)(1)(F) automatically excludes all time from the filing of a pretrial motion through the conclusion of the hearing, without a “reasonably necessary” limitation.
- The Court held that § 3161(h)(1)(F) also excludes post-hearing time when the district court is awaiting additional submissions needed for proper disposition of the motion.
- The Court left the convictions intact because the challenged period was properly excluded from the Speedy Trial Act calculation.
Legal Principles
- Under § 3161(h)(1)(F), the period from filing a pretrial motion through completion of the hearing on that motion is excluded from the Speedy Trial Act’s 70-day trial clock, regardless of whether the hearing was prompt.
- The phrase “or other prompt disposition” addresses motions decided without a hearing; it does not impose a general reasonableness limit on delay in holding a hearing.
- Post-hearing time is excludable under § 3161(h)(1)(F) when the court is awaiting necessary filings requested or required to resolve the motion.
- When Congress intended a “reasonable period of delay” limitation, it said so expressly elsewhere in § 3161(h); the absence of that language in subsection (F) indicates an automatic exclusion.
- In joint trials, Speedy Trial Act computations generally track the latest codefendant, and exclusions applicable to one codefendant may affect all joined defendants.
Conclusion
The Court interpreted the Speedy Trial Act’s motion-related exclusion to toll the 70-day clock automatically from the filing of a pretrial motion through the hearing (and through necessary post-hearing submissions required for decision), rejecting any implied “reasonably necessary” constraint in § 3161(h)(1)(F).