United States v. Edward Treisback, 694 F. App'x 678

In May 2011 agents executed a search warrant at Treisback’s home and seized computers and drives containing images of prepubescent girls in sexual acts; initial federal grand jury indictments followed in June 2011.
The district court dismissed three earlier indictments without prejudice under the Speedy Trial Act prior to the final indictment.
A fourth (final) indictment issued June 11, 2014 (one count of receipt, one count of possession of child pornography); trial was set for August 25, 2014 and ultimately held December 14–15, 2015.
Trial delays between the final indictment and trial resulted largely from defendant’s actions: requests for competency evaluations after self-inflicted wounds and multiple requests for substitute counsel, which he acknowledged would delay trial.
On the first day of trial counsel renewed a motion to dismiss the fourth indictment on speedy-trial grounds; the district court implicitly denied the motion, tried the case, and convicted Treisback; sentences were reduced to account for pretrial custody time.
Treisback appealed, arguing the district court erred in denying dismissal of the fourth indictment for violation of his Sixth Amendment right to a speedy trial.

Issue	Plaintiff's Argument (Treisback)	Defendant's Argument (Government)	Held
Whether the district court violated the Sixth Amendment right to a speedy trial by denying Treisback’s renewed motion to dismiss the fourth indictment	The court failed to make factual findings or legal analysis under Barker and thus should have dismissed the indictment for constitutional speedy‑trial violations	Delays were largely attributable to Treisback (competency evaluations, counsel changes); any delay was justified or excluded; no significant prejudice shown	Affirmed: balancing Barker factors, the government did not deny Treisback a constitutional speedy trial

United States v. Harris, 376 F.3d 1282 (11th Cir. 2004) (standard of de novo review for speedy‑trial dismissal)
United States v. Villarreal, 613 F.3d 1344 (11th Cir. 2010) (mixed question of law and fact; review framework)
Barker v. Wingo, 407 U.S. 514 (1972) (four‑factor speedy‑trial balancing test)
United States v. Stefan, 784 F.2d 1093 (11th Cir. 1986) (failure to rule may be treated as implicit denial)
United States v. McDaniel, 631 F.3d 1204 (11th Cir. 2011) (only delay after final indictment counts for Sixth Amendment analysis)
United States v. Ingram, 446 F.3d 1332 (11th Cir. 2006) (delays exceeding one year are presumptively prejudicial)