United States v. Erickson
0:24-cr-00007
| D. Minnesota | Apr 23, 2025Background
- David V. Erickson was indicted on multiple counts of tax evasion, assisting in the preparation of false tax returns, and making a false statement to the IRS.
- The case was designated as “complex” due to the nature of the charges, extensive foreign evidence, numerous foreign witnesses, voluminous discovery exceeding half a million pages, and ongoing evidence collection.
- The initial trial date set for May 20, 2024, was later moved to May 12, 2025, with the exclusion of 426 days from the Speedy Trial Act clock.
- The government sought additional time for foreign witness depositions and managing complex discovery disputes; Erickson generally requested a quicker trial timeline consistent with his speedy trial rights.
- Multiple pretrial motions and evidentiary issues remain pending, underscoring the case’s continued complexity and the need for more preparation time.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclude more time as "complex case" | The case’s complexity justifies more time | No further exclusion; trial by June 23, 2025 | More time excluded; trial set for August 4, 2025 |
| Speedy Trial Act application | Interests served by delay outweigh speedy trial | Time exclusion violates speedy trial rights | Delay justified under Speedy Trial Act |
| Sixth Amendment right to a speedy trial | No violation given reasonable delays, complexity | Delay violates constitutional speedy trial | No Sixth Amendment violation found |
| Scheduling of foreign depositions | Need additional time for depositions and review | Sought to delay depositions for more prep | Depositions to occur in May 2025; trial after |
Key Cases Cited
- United States v. Johnson, 990 F.3d 661 (8th Cir. 2021) (clarifies oral or written reasoning is required for Speedy Trial Act exclusions)
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (establishes factors to evaluate a Sixth Amendment speedy trial violation)
- United States v. Aldaco, 477 F.3d 1008 (8th Cir. 2007) (noting that a Sixth Amendment violation is unusual if there is no Speedy Trial Act violation)