United States v. Brown, No. 22-3797 (6th Cir. 2024)
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The case involves Carlos Brown, a defendant who was indicted on fraud and identity theft charges related to a credit card scheme. Brown argued that his right to a speedy trial, as stipulated by the Speedy Trial Act, was violated twice during the 1,176 days between his arraignment and his guilty plea. The first violation involved a 36-day delay in transporting Brown from Ohio to the Federal Medical Center in Lexington for his competency evaluation. The second violation involved a 21-day period after the denial of Brown’s first motion to dismiss.
The district court denied both of Brown's motions to dismiss. It ruled that the 36-day delay was excludable and entered a 21-day retroactive ends-of-justice continuance after denying Brown's first motion to dismiss.
The United States Court of Appeals for the Sixth Circuit found that the district court erred in denying both motions. The court held that the 36-day delay in transporting Brown was not excludable and that the district court abused its discretion by not properly placing its reasoning for the 21-day retroactive ends-of-justice continuance on the record. As a result, the court vacated Brown's conviction and remanded the case to the district court to determine whether his indictment should be dismissed with or without prejudice.
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