United States v. Martin, 4:21-cr-00070

Defendant Christopher Martin was arraigned Sept. 23, 2021; a three-day jury trial originally set for Dec. 7, 2021.
Magistrate judge granted a 90-day continuance on Nov. 23, 2021, moving trial to Mar. 21, 2022; earlier court orders had excluded time under the Speedy Trial Act because of COVID-19.
Martin moved for a second continuance (120 days) under 18 U.S.C. § 3161(h)(7) to allow for preparation, ongoing discovery, and plea negotiations; defendant is in custody and consents.
The U.S. Attorney stipulated to the requested continuance.
The District of Utah had issued multiple COVID-19 general orders finding public-health, logistical, and access-to-defendant impairments that justified excluding time under the Speedy Trial Act.
The court concluded the interests of justice outweighed speedy-trial interests and granted the continuance to July 19, 2022, excluding the period from Speedy Trial calculations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to grant continuance and exclude time under 18 U.S.C. § 3161(h)(7)	Gov't stipulated and supported ends-of-justice exclusion to permit fair preparation and protect health	Martin sought more time due to COVID-19 restrictions, limited access to detained client, ongoing discovery and plea talks	Granted: trial continued to July 19, 2022; time excluded under § 3161(h)(7)
Whether pandemic-based findings satisfy Toombs standard (ends-of-justice not mere congestion)	Court-wide general orders and specific COVID-19 findings justify exclusion as an exceptional circumstance	Defense relied on the same factual findings (reduced access, safety risks, preparation limits) to support exclusion	Court: pandemic conditions, logistical limits, and discovery/plea status satisfy Toombs factors; exclusion appropriate

United States v. Toombs, 574 F.3d 1262 (10th Cir. 2009) (explaining ends-of-justice exclusion is disfavored and must be supported by specific findings; used as the controlling standard for § 3161(h)(7) determinations)