United States v. Kohn
2:25-cr-01030
N.D. IowaAug 6, 2025Background
- This case is a criminal matter pending in the United States District Court for the Northern District of Iowa against defendants Spencer William Kohn, Ryan Michael Zalaznik, and Christopher John Davis.
- Defendant Kohn filed an unopposed motion to continue the scheduled trial date and the pretrial motion deadline.
- Trial was originally set for September 8, 2025; Kohn requested the trial and pretrial deadlines be extended.
- The government and co-defendants did not resist Kohn’s motion to continue.
- The court considered whether there was a compelling reason for the continuance and weighed it against public and defendant interests, including the Speedy Trial Act.
- The Court granted the continuance, setting a new trial period beginning November 17, 2025, and extended pretrial motion deadlines accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to grant a continuance of the trial date and pretrial motion deadline | No objection | Good cause exists for continuance; reasons serve justice | Continuance granted; new trial and motion deadlines set |
| Whether time from motion to new trial is excludable under the Speedy Trial Act | No objection | Continuance should be excludable; outweighs right to speedy trial | Time is excluded under 18 U.S.C. § 3161(h)(7)(A) |
| Whether the interests of justice warrant delay over the public and defendant’s speedy trial rights | Not opposed | Continuation serves the interests of justice | Interests of justice outweigh Speedy Trial concerns |
| Whether trial management orders continue to govern with new trial dates | Not addressed | Orders should continue with new dates | Prior management orders remain in effect with new schedule |
Key Cases Cited
- United States v. Jirak, 728 F.3d 806 (8th Cir. 2013) (standard for granting a continuance and the court’s discretion)
- United States v. Cotroneo, 89 F.3d 510 (8th Cir. 1996) (requirement for compelling reason for continuance)
- United States v. Farlee, 757 F.3d 810 (8th Cir. 2014) (factors balancing continuance requests)
- United States v. Coronel–Quintana, 752 F.2d 1284 (8th Cir. 1985) (balancing need for continuance against delay hardship)
- United States v. Moe, 536 F.3d 825 (8th Cir. 2008) (Speedy Trial Act considerations)
- United States v. Roberts, 787 F.3d 1204 (8th Cir. 2015) (timeliness and excludable delay under Speedy Trial Act)
- United States v. Dunn, 723 F.3d 919 (8th Cir. 2013) (consideration of delay prejudice and Speedy Trial Act)
- Morris v. Slappy, 461 U.S. 1 (1983) (broad trial court discretion in granting continuances)
