United States v. James Mathurin, 690 F.3d 1236

Mathurin, 17, was convicted of multiple armed-robbery and weapons offenses arising from a five-month Miami-Dade crime spree.
The Speedy Trial Act requires indictment within 30 days of arrest, with automatic exclusions for certain proceedings, including plea negotiations under § 3161(h)(1)(G).
Juvenile information filed April 1, 2009 charged 49 offenses; the government sought adult prosecution and Mathurin was transferred to adult status on August 27, 2009.
Plea negotiations occurred between August 2009 and December 2009, with a status conference on December 22, 2009 and a subsequent indictment on December 29, 2009; a superseding indictment followed in April 2010.
The district court denied dismissal under the Speedy Trial Act; Mathurin appealed contending the indictment was untimely.
The issue on appeal is whether time during plea negotiations is automatically excludable from the Speedy Trial Act’s 30-day window.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is plea negotiation time automatically excludable under §3161(h)(1)(G)?	Mathurin argues such delay is not automatically excludable.	Government contends plea negotiations fall within the automatic exclusion for plea proceedings.	No; plea negotiations are not automatically excludable under §3161(h)(1)(G).
May ends-of-justice tolling apply to plea-negotiation delays beyond automatic exclusion?	Ends-of-justice tolling does not apply to this delay.	Ends-of-justice tolling may permit additional delay when public interest in justice outweighs speedy-trial interests.	Yes; ends-of-justice tolling can apply, but requires court findings and is not automatic.
Are waiver or estoppel defenses available to excuse pre-indictment delay due to plea talks?	Waiver/estoppel could bar the claim to dismissal.	Waiver/estoppel defenses may apply to pre-indictment delay.	No; neither waiver nor estoppel applies to bar the Act here.
What is the impact of the plea-negotiation delay on the initial speedy-indictment clock in this case?	Delay breached the 30-day requirement for indictment.	Delay tolls the clock under §3161(h)(1) or ends-of-justice where appropriate.	The delay was not automatically excludable; the clock was exceeded, requiring dismissal or vacatur of convictions.

Bloate v. United States, 130 S. Ct. 1345 (2010) (limits automatic excludability of delays under §3161(h)(1))
Zedner v. United States, 547 U.S. 489 (2006) (no-waiver policy; public interest in speedy trial)
United States v. Pete, 525 F.3d 844 (9th Cir. 2008) (start of speedy-indictment clock upon adult status transfer)
United States v. Lucky, 569 F.3d 101 (2d Cir. 2009) (plea negotiations not comfortably within ‘other proceedings’)
United States v. Leftenant, 341 F.3d 338 (4th Cir. 2003) (plea negotiations as potential ‘other proceedings’)
United States v. Bowers, 834 F.2d 607 (6th Cir. 1987) (plea bargaining discussed in context of timing)