United States v. Tinklenberg

Background

Jason Louis Tinklenberg was convicted of federal gun and drug crimes. He first appeared before a judge on October 31, 2005, and his trial began 287 days later. He moved to dismiss the indictment for violating the Speedy Trial Act’s 70-day rule. The District Court counted many excluded periods and found the trial timely. The Sixth Circuit disagreed about three short pretrial motions and applied a test requiring each motion to have actually caused a trial delay, ordered dismissal, and the Government sought review.

Reasoning

The central question was whether the Act excludes time automatically from the filing through the disposition of any pretrial motion, or only when the motion actually delays the trial. The Court held the exclusion applies automatically from filing to disposition. It relied on the statute’s wording, structure, prior decisions, the uniform view of other appeals courts, and administrative practicality. The Court reversed the Sixth Circuit’s causation requirement. The Court also resolved a separate timing issue about transportation for a competency exam, concluding weekends and holidays count in the statute’s ten-day rule.

Real world impact

Federal trial judges, prosecutors, defense lawyers, and defendants will count the time a pretrial motion is pending as excluded without a separate finding that the motion postponed trial. Courts must include weekend and holiday days when measuring the ten-day transportation presumption. Those changes reduce the usefulness of a motion-by-motion causation strategy to obtain dismissal under the Speedy Trial Act.

Dissents or concurrances

Justice Scalia, joined by two others, wrote separately to emphasize that the Act’s text alone clearly supports automatic exclusion and to join the judgment.