United States v. Cadarr

Background

Respondents were indicted in Washington, D.C., for conspiracy after being held to await action by a grand jury (the group that decides whether to bring formal charges). One defendant moved to quash because the grand jury had not acted within nine months of the date he was held to bail. The District Court discharged him and released his bail; the Court of Appeals affirmed that result, and the case reached this Court for review.

Reasoning

The Court asked whether the D.C. statute that calls prosecution "abandoned" if the grand jury fails to act within nine months was meant to be a permanent time limit on prosecuting the crime, or only a rule about freeing someone who was jailed or on bond while the grand jury delayed. The Court concluded the statute governs the grand jury’s timing and the accused’s immediate liberty — it lets a jailed person be set free or bail discharged when the grand jury does not act — but it does not say that the person is forever protected from later prosecution. The Court relied on the statute’s wording and compared it to the separate general law that sets ordinary time limits to start prosecution (the statute of limitations).

Real world impact

People in D.C. who are held awaiting grand‑jury action can be freed if the grand jury sits silent for nine months, but the government remains able to bring formal charges later if it does so within the ordinary time limits for starting prosecution. The Court reversed the lower courts and sent the case back for further proceedings.