United States v. Tinklenberg

Background

Jason Tinklenberg, a man charged with federal drug and gun offenses, went to trial 287 days after his arraignment. He moved to dismiss under the Speedy Trial Act’s 70‑day rule. The District Court found 218 days excludable and ruled the trial timely. The Sixth Circuit disagreed about nine days tied to three pretrial motions and found the trial untimely, ordered dismissal with prejudice because Tinklenberg had already served his sentence, and the Government asked the Supreme Court to review.

Reasoning

The central question was whether the Speedy Trial Act excludes time automatically when a pretrial motion is filed or only when the motion actually delays the trial. The Court held that filing a pretrial motion automatically pauses the 70‑day clock, explaining that the statute’s structure, consistent decisions by other appeals courts, administrative practicality, and precedent support automatic application. The Court also interpreted the transportation exclusion to count weekend and holiday days in its ten‑day limit and rejected importing Rule 45 into the statute. Although the Court found the Sixth Circuit wrong about both provisions, it concluded those errors offset each other.

Real world impact

The ruling clarifies how courts count time under the Speedy Trial Act: filing common pretrial motions routinely suspends the deadline, making time computation more predictable and easier to administer. It also affects how transportation time is counted by including weekends and holidays in the ten‑day measure. In this specific case the Supreme Court affirmed the lower court’s judgment ordering dismissal.

Dissents or concurrances

Justice Scalia, joined by the Chief Justice and Justice Thomas, wrote separately agreeing with the judgment and emphasizing that the statute’s text plainly supports automatic exclusion. Justice Kagan took no part.