United States v. Jackson
6:24-cr-10010
D. Kan.May 15, 2025Background
- Sidney Jamar Jackson moved to suppress evidence, claiming it was obtained through a warrantless search, allegedly violating the Fourth Amendment.
- The motion was fully briefed and heard on April 16, 2025; the court took the matter under advisement at that time.
- Under the Speedy Trial Act, the time from filing the suppression motion until the court's ruling is excludable from the speedy trial calculation, with an automatic 30-day limit after the court takes the motion under advisement.
- The 30-day excludable period was set to expire on May 16, 2025.
- The court determined that because the motion concerns complex and novel legal questions regarding the Fourth Amendment and emerging technologies, additional time to resolve the motion was justified.
- The court ordered an additional 30-day exclusion from the speedy trial calculation, finding it was warranted and would not prejudice the defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to exclude time beyond the initial 30-day period under the Speedy Trial Act due to complex legal issues | Complex, novel issues justify extra time for court | Speedy disposition is in defendant’s interest | Extension of excludable time granted; not prejudicial |
Key Cases Cited
- Henderson v. United States, 476 U.S. 321 (1986) (interpreting the Speedy Trial Act's provisions regarding time excluded while motions are pending)
- United States v. Mora, 135 F.3d 1351 (10th Cir. 1998) (remanding and ordering dismissal where suppression motion was pending excessively under the Speedy Trial Act)
- United States v. Toombs, 574 F.3d 1262 (10th Cir. 2009) (requiring reasons for continuances under the Speedy Trial Act)