United States v. Tinklenberg
The Court ruled that under the Speedy Trial Act, the mere filing of a pretrial motion automatically stops the 70-day trial clock while it's pending, whether or not the motion actually pushed back the trial date.
The Court also rejected the government's method for counting transportation delays, but the two errors offset each other, so the defendant's conviction was still thrown out because his trial came too late.
How it got here: A federal district court found the trial timely; the Sixth Circuit reversed and ordered the indictment dismissed; the government sought Supreme Court review.
The Case in Depth
What happened
Jason Tinklenberg was convicted of federal drug and gun charges. His trial began 287 days after his first court appearance, far more than the 70 days the Speedy Trial Act normally allows. He argued the delay violated the Act, pointing to pretrial motions and a competency-related transportation period he said should not have been excluded from the 70-day count.
The question before the Court
When counting the 70 days a federal criminal trial has to start, does a pretrial motion pause the clock only if it actually delayed the trial?
Why it matters
Federal trial judges and prosecutors now have a clear, easy-to-apply rule: filing a pretrial motion pauses the speedy-trial clock automatically, without requiring courts to sort out whether each motion actually pushed back the trial date. That avoids messy after-the-fact litigation over causation in thousands of federal criminal cases each year, even though it meant this particular defendant's conviction was still vacated.
What changes now
This is a final merits decision, not a remand for further fact-finding. Because the two legal corrections offset each other, the Sixth Circuit's bottom-line conclusion that Tinklenberg's trial violated the Speedy Trial Act stands, and the order dismissing his indictment with prejudice is affirmed. Lower federal courts nationwide will now apply the automatic, no-causation-required reading of the pretrial-motion exclusion going forward.
What this does not decide
The Court did not decide whether every one of the Act's other delay exclusions works the same way, though it noted similar reasoning likely applies to related provisions. It also did not revisit whether Tinklenberg's sentence, already served, entitled him to any additional relief beyond dismissal of the indictment.
Concurrences and dissents
Concurrence in part — Justice Scalia
Justice Scalia agreed that a pretrial motion need not actually postpone a trial to pause the speedy-trial clock, and agreed with the outcome, but relied solely on the statute's text and structure rather than legislative history or policy concerns about administrability. He argued the text alone made the answer 'entirely clear' and that circuit unanimity followed from textual clarity, not the reverse.
How the Court got there
The legal reasoning, step by step
- The Court examined whether the Speedy Trial Act's exclusion for 'delay resulting from any pretrial motion' requires proof that the motion actually postponed the trial, or the expectation of a postponement.
- It found the text alone didn't resolve the question, because 'delay' could mean either an actual postponement or simply the interval of time a motion was pending, and the statute's structure supported treating pending-motion periods as excludable by definition.
- Several considerations tipped the balance: every other circuit had rejected a causation requirement for 37 years, a causation test would be extremely hard for trial judges to administer in advance, and the Court's precedent in Henderson v. United States described this kind of exclusion as automatic.
- Applying that automatic reading, the Court held the nine days the three pretrial motions were pending in this case were excludable regardless of whether they actually delayed the trial.
- Separately, the Court considered whether the transportation-delay provision excludes weekends and holidays by incorporating a federal procedural rule, and concluded it does not, so weekend days and holidays count toward the 10-day transportation limit under the ordinary common-law counting rule.
- Because the transportation ruling added excludable days back into the government's favor while the pretrial-motion ruling removed some of the defendant's favorable days, the two corrections canceled out, leaving the trial over the 70-day limit either way.
Doctrinal impact
Cases affected by this decision
Reaffirms Henderson v. United States (476 U. S. 321)
The Court relied on Henderson's rule that the pretrial-motion exclusion applies automatically without case-by-case findings.
Reaffirms Bloate v. United States
Cited as support that Speedy Trial Act exclusions apply automatically to specified periods of delay.