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United States v. Kohn
2:25-cr-01030
N.D. Iowa
Aug 6, 2025
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Background

  • 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)
Read the full case

Case Details

Case Name: United States v. Kohn
Court Name: District Court, N.D. Iowa
Date Published: Aug 6, 2025
Citation: 2:25-cr-01030
Docket Number: 2:25-cr-01030
Court Abbreviation: N.D. Iowa