United States v. Clifton Satterwhite, 893 F.3d 352

Satterwhite was arrested January 22, 2016; government sought charges under the Hobbs Act and § 924(c).
The Speedy Trial Act (STA) normally requires an indictment/information within 30 days of arrest; the parties jointly moved for and the district court granted successive 30‑day extensions under the "ends of justice" provision, extending the deadline to August 21, 2016.
The government filed an information on October 7, 2016 (after the extended deadline); Satterwhite pleaded guilty the same day pursuant to a binding plea agreement recommending 240 months and waiving appeal of the sentence.
The district court sentenced Satterwhite to 240 months on April 18, 2017; Satterwhite did not move to dismiss the untimely information in the district court before pleading guilty.
On appeal Satterwhite argued the untimely filing deprived the district court of jurisdiction because § 3161(b)’s 30‑day indictment deadline is jurisdictional; the Sixth Circuit reviewed the question de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the STA 30‑day indictment/information deadline (§ 3161(b)) is jurisdictional	Satterwhite: the 30‑day rule is jurisdictional so untimely filing deprived the court of power and cannot be waived	Government: the STA time limit is a claim‑processing rule; defendant waived the issue by pleading guilty without moving to dismiss	The 30‑day rule is not jurisdictional; it is a claim‑processing rule and Satterwhite waived the challenge by pleading guilty

Tollett v. Henderson, 411 U.S. 258 (Sup. Ct. 1973) (guilty plea waives nonjurisdictional antecedent defects)
Class v. United States, 138 S. Ct. 798 (Sup. Ct. 2018) (plea‑waiver principles reaffirmed)
Kontrick v. Ryan, 540 U.S. 443 (Sup. Ct. 2004) (distinguishing jurisdictional rules from claim‑processing rules)
Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428 (Sup. Ct. 2011) (counsels against labeling rules as jurisdictional absent clear congressional intent)
Union Pac. R.R. Co. v. Bhd. of Locomotive Engineers & Trainmen, 558 U.S. 67 (Sup. Ct. 2009) (subject‑matter jurisdiction cannot be forfeited; claim‑processing rules ordinarily can)
Arbaugh v. Y & H Corp., 546 U.S. 500 (Sup. Ct. 2006) (clarifies when statutory limitations are jurisdictional)
Zedner v. United States, 547 U.S. 489 (Sup. Ct. 2006) (interpretation of STA and purposes of § 3162(a)(2))
United States v. Cherry, 720 F.3d 161 (4th Cir. 2013) (holding § 3162(a)(2) waiver applies to untimely indictment under § 3162(a)(1))
United States v. Hines, 694 F.3d 112 (D.C. Cir. 2012) (same)
United States v. Spagnuolo, 469 F.3d 39 (1st Cir. 2006) (same)