Term: 2009
Docket: 08-728
Taylor James Bloate v. United States
- Pro
08-728 BLOATE V. UNITED STATES DECISION BELOW: 534 F.3d 893 CERT. GRANTED 4/20/2009 QUESTION PRESENTED: The Speedy Trial Act, 18 U.S.C. § 3161 et seq., requires that a criminal defendant be tried within 70 days of indictment or the defendant's first appearance in court, whichever is later. In calculating the 70-day period, 18 U.S.C. § 3161(h)(1) automatically excludes "delay resulting from other proceedings concerning the defendant, including but not limited to * * * (D) delay resulting from any pretrial motion, from the filing of the motion through the conclusion of the hearing on, or other prompt disposition of, such motion" (emphasis added). The question presented here is: Whether time granted to prepare pretrial motions is excludable under § 3161(h)(1). As the Eighth Circuit explicitly acknowledged below, this question has divided the courts of appeals. The Fourth and Sixth Circuits have answered it in the negative; the Eighth Circuit and seven other circuits have answered it in the affirmative. LOWER COURT CASE NUMBER: 07-2357
In the case of Taylor James Bloate v. United States, 2009, the Supreme Court ruled on a dispute regarding how time is calculated for preparation of pretrial motions under the Speedy Trial Act (STA). The STA mandates that a defendant's trial must commence within 70 days from their first appearance in court or indictment, whichever comes later. However, it allows certain periods to be excluded from this calculation including "delay resulting from any pretrial motion". Bloate was indicted on gun and drug charges but his trial did not start until well after the 70-day limit due to time spent preparing pretrial motions. He argued that this violated his rights under STA as only actual hearing times were excludable delays and not preparation times. The District Court disagreed with him but was overturned by Eighth Circuit which sided with Bloate’s interpretation of law. However, upon reaching Supreme Court, it reversed Eighth Circuit’s decision stating that while some exclusions require hearings others do not; hence all delay resulting from any 'pretrial motion' can be excluded without needing separate findings justifying exclusion of related preparation time.
In the dissenting opinion for Bloate v. United States, Justice Alito argued that the majority's interpretation of the Speedy Trial Act was incorrect and overly narrow. He contended that pretrial motion preparation time should be automatically included in calculating delays under the Act, as it is an essential part of trial proceedings. The majority’s decision to exclude this period from automatic inclusion could lead to unnecessary litigation over what constitutes delay and complicate matters further by requiring judges to determine whether such periods are reasonable or not on a case-by-case basis. This would ultimately undermine one of the main purposes of the Speedy Trial Act: providing clear rules to ensure speedy trials.
