United States v. Maryea, 704 F.3d 55

Maryea was convicted by jury of conspiracy to possess with intent to distribute several controlled substances in a multi-defendant case.
The original indictment charged fourteen co-defendants; a superseding indictment later named only Maryea and Woods and extended the conspiracy period from April 2009 to September 20, 2009.
Woods moved for a court-ordered continuance; the district court granted Woods' first and second continuances, affecting the trial schedule and Speedy Trial Act calculations.
The district court denied Maryea's motion to dismiss under the Speedy Trial Act and declined to sever the co-defendant's case for purposes of evaluating the delay as to Maryea.
Before trial, the court ordered a competency evaluation for Maryea; after a car accident during trial, the court ordered further medical evaluation and scheduled proceedings to assess ongoing competency.
Maryea was injured, received pain management, and the trial continued after interim delays; the court ultimately reconvened and the jury returned a guilty verdict on the superseding indictment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Speedy Trial Act—excludable time	Maryea argued the Second MTC delay was unreasonable for her clock.	Maryea asserted a co-defendant delay should be assessed for reasonableness as to her without severance.	Delay to Woods was reasonable to Maryea; no Speedy Trial violation.
Competency re-evaluation after accident	Maryea claimed the accident change of circumstances required a second competency hearing.	Government contended no new hearing was required; existing competency findings stood.	No abuse of discretion; no second competency hearing required.
Prejudicial variance from indictment	Variance between Woods-dominated trial evidence and the superseding indictment against Maryea prejudiced her.	Evidence supported a single overarching conspiracy; no prejudicial variance reached.	No prejudicial variance; conviction upheld.

Bloate v. United States, 130 S. Ct. 1345 (2010) (reasonableness findings may justify exclusions under §3161(h)(7))
Zedner v. United States, 547 U.S. 489 (2006) (speedy-trial continuances must fit within §3161(h) exclusions)
Sánchez-Ramírez, 570 F.3d 75 (1st Cir. 2009) (no abuse where prior competency finding remains valid post-accident)
Dellosantos, 649 F.3d 109 (1st Cir. 2011) (variance analysis when multiple conspiracies; sufficiency review)
Sánchez-Badillo, 540 F.3d 24 (1st Cir. 2008) (common goal and interdependence support single conspiracy)