993 F.3d 550
8th Cir.2021Background
- Law enforcement conducted a controlled delivery on May 13, 2015 of four kilograms of methamphetamine; Flores-Lagonas met a cooperating individual in a shopping-center parking lot with passenger Perez-Juarez.
- Unmarked officers approached the Pacifica with weapons drawn and announced themselves as police; Flores-Lagonas did not submit and drove away.
- A high-speed chase followed; Flores-Lagonas collided with a police Jeep, discarded suspected narcotics, lost control, fled on foot, and was captured. Officers found two loaded magazines on him and a handgun plus another magazine in the vehicle; he admitted possession.
- Flores-Lagonas was indicted July 14, 2015 on drug and firearm counts and moved to suppress the seized evidence; the magistrate and district courts denied suppression.
- Nearly four years elapsed before he pleaded guilty on June 4, 2019 (preserving suppression and dismissal appeals); the delay resulted mainly from competency proceedings, defense continuances, and the addition of co-defendants. He was sentenced to 156 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fourth Amendment (stop/seizure & probable cause to arrest/search) | Flores-Lagonas contends officers effected an unlawful seizure in the parking lot without reasonable suspicion and lacked probable cause to arrest/search. | Officers did not seize him in the lot because he fled; after flight, collision, high-speed and reckless driving they had probable cause to arrest and search. | No seizure in the lot (no submission); arrest supported by probable cause based on flight and reckless driving; suppression denied. |
| Perjury / Due Process (Napue) | Officers perjured themselves at the suppression hearing; prosecution allowed false testimony, violating due process. | No convincing evidence of perjury; video does not meaningfully contradict testimony; materiality and government knowledge not shown. | Motion to dismiss/reconsider denied; no due process violation established. |
| Sixth Amendment speedy trial | ~4-year delay from indictment to plea violated his Sixth Amendment right to a speedy trial. | Delay was largely caused by Flores-Lagonas (competency proceedings, continuances); government delay was justified by joinder and preparation. | Barker factors favor government (defense caused most delay; no specific prejudice shown); no Sixth Amendment violation. |
| Speedy Trial Act (18 U.S.C. § 3161) | Court improperly excluded time for counsel continuances, superceding indictment/co-defendant joinder, and competency proceedings. | Exclusions fall within §3161(h): competency proceedings, ends-of-justice continuances, and reset of the speedy-clock on joinder of new defendants. | Exclusions were proper; 70-day limit had not run at plea. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (establishes show-of-authority seizure framework)
- California v. Hodari D., 499 U.S. 621 (no seizure unless person submits to police show of authority)
- Atwater v. City of Lago Vista, 532 U.S. 318 (officers may arrest without a warrant if there is probable cause even for minor offenses)
- Devenpeck v. Alford, 543 U.S. 146 (probable cause judged by facts known to arresting officer)
- Napue v. Illinois, 360 U.S. 264 (prosecution use of known false testimony violates due process)
- Barker v. Wingo, 407 U.S. 514 (four-factor speedy-trial balancing test)
- Doggett v. United States, 505 U.S. 647 (presumptive prejudice from excessive delay can factor into Barker analysis)
- United States v. Lightfoot, 483 F.3d 876 (joinder of newly indicted defendants resets speedy-trial clock)