## Facts

- The United States prosecuted Frank Reaves, Jr. and Harold Shapot for criminal tax fraud involving purported coal mining partnerships allegedly formed to generate fraudulent tax deductions rather than conduct mining.
- At a pretrial conference, the government estimated its case-in-chief would require about a month.
- The court found the estimate excessive because the government planned to present voluminous tax-return evidence page by page, with little effort to organize the proof using summaries or charts.
- The court noted Federal Rule of Evidence 1006 permits summaries of voluminous writings and viewed the government’s proposed presentation as wasteful and duplicative.
- Pretrial, the court entered a scheduling order imposing time limits on stages of trial, including a fixed number of days for the government’s case-in-chief.
- Both the government and defendants challenged the court’s authority to impose such time limits in a criminal case.

## Issues

1. Whether a federal district court may impose reasonable, preannounced time limits on the parties’ presentation of evidence in a criminal trial to reduce cumulative and time-wasting proof.
2. What constraints must apply to ensure time limits do not deny either side a fair opportunity to present material evidence.

## Decision

- The court held it has authority to impose reasonable time limits on the presentation of evidence in a criminal trial.
- The court concluded such limits must be flexible and subject to modification for good cause when additional time is needed to present material evidence.
- The court maintained its scheduling order limiting the government’s case-in-chief, while emphasizing it could be adjusted during trial if necessary.

## Legal Principles

- Federal trial courts possess inherent authority and a duty to manage proceedings efficiently and to prevent cumulative, duplicative, or time-wasting proof.
- Trial time limits are permissible if set reasonably in light of the case’s needs and imposed with informed consideration of the anticipated proof.
- Time limits must not operate as arbitrary caps that exclude material evidence; they should target cumulative presentation rather than essential proof.
- Courts may require or encourage streamlined methods of presenting voluminous evidence, including summaries contemplated by Federal Rule of Evidence 1006.

## Conclusion

The district court upheld its power to impose reasonable, preannounced, and adjustable time limits in a criminal trial as a case-management tool to reduce cumulative evidence while preserving each party’s ability to present material proof and obtain additional time upon a sufficient showing.


United States v. Reaves, 636 F. Supp. 1575 (E.D. Ky. 1986)