Criminal Law: Speedy Trial Act – Length Of Delay – Tolling

Where a defendant, who claimed violations of the Speedy Trial Act after spending more than 400 days in jail awaiting trial, traveled out-of-state to cooperate with the government to reduce his sentence, the delay was not of such length to eliminate the need to show particularized prejudice and there was no evidence that the delay impeded the defense or threatened to deprive him of a fair trial, there was no Sixth Amendment violation, and the district court did not err in excluding the entire period that the defendant’s pro se motions were pending because each motion, whether he was represented or not, tolled the speedy trial clock.

Judgment is affirmed.

U.S. v. Williams (MLW No. 58701/Case No. 08-1269 – 15 pages) (U.S. Court of Appeals, Eighth Circuit, Murphy, J.) Appealed from U.S. District Court, District of Minnesota, Kyle, J. (Andrea K. George, Minneapolis, argued for appellant) (Andrew Robert Winter, Minneapolis, argued for appellee).