Speedy trial deadlines
United States v. Tinklenberg
In brief
The Supreme Court left intact the finding that Tinklenberg’s trial missed the deadline and confirmed that pending-motion time is excluded even if it causes no delay.
- Where it stands
- Decided
Decided 8-0 · May 26, 2011 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court ruled that the Speedy Trial Act excludes the time a pretrial motion is pending even if it did not actually delay, or was not expected to delay, the trial.
- Who it affects
- Federal courts must leave time when a pretrial motion is pending out of the Speedy Trial Act’s 70-day count, whether or not the motion delays trial.
Summary: written with AI from the case record.
What it's about
The Court upheld the lower court’s conclusion that Jason Tinklenberg’s trial missed the deadline because errors in its readings of the motion and transportation rules canceled each other out.
The lower courts agreed that transporting Tinklenberg for a competency evaluation took 20 days and that the government gave no reason for 10 days beyond the statute’s 10-day allowance.
The Speedy Trial Act’s 70-day deadline leaves certain periods out of the count, including time tied to pretrial motions and transportation for evaluations.
Question presented
Is the time between the filing of a pretrial motion and its disposition automatically excluded from the deadline for commencing trial under the Speedy Trial Act?
What the Court decided
Holding
The Sixth Circuit also misinterpreted §3161(h)(1)(F), which excludes from the 70-day calculation “delay resulting from transporta- tion of any defendant... to and from places of examination..., except that any time consumed in excess of ten days... shall be presumed to be unreasonable.” The lower courts agreed that a total of 20 transportation days had elapsed when Tinklenberg was evaluated for competency, and that because the Government provided no justification, all days in excess of the 10 days specified in the statute were unreasonable. Although the Sixth Circuit’s interpretations of subparagraphs (D) and (F) are both mistaken, the conclusions the court drew from its interpretations in relevant part cancel each other out, such that the court’s ultimate conclusion that Tinklenberg’s trial failed to comply with the Act’s deadline is correct. 579 F. 3d 589, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said the Sixth Circuit misread both the pending-motion rule and the rule for transportation to an evaluation. The two errors canceled each other out in the calculation, leaving correct the conclusion that Tinklenberg’s trial missed the 70-day deadline.
The vote
What's next
The finding that Tinklenberg’s trial missed the deadline remains in place. Courts applying the Act must use the pending-motion exclusion when counting the 70-day deadline.
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Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.