United States v. Nathan Mattocks, 23-4271

Nathan Mattocks was initially arrested in August 2020 by the Commonwealth of Virginia on state charges.
On January 28, 2021, the U.S. government filed a federal criminal complaint, issued a federal arrest warrant, and sent a federal detainer to Virginia authorities.
Virginia resolved its charges against Mattocks on February 1, 2021, but Mattocks remained in custody based on the federal detainer.
U.S. Marshals arrested Mattocks on February 3, and he was ordered detained after a federal hearing on February 10.
Mattocks was indicted federally on March 5, 2021, on drug and firearm charges.
Mattocks moved to dismiss the indictment, arguing the federal indictment was untimely under the Speedy Trial Act; the district court denied his motion.

Issue	Mattocks's Argument	Government's Argument	Held
When did the federal speedy trial clock start?	Federal restraint began with detainer/state custody end	Detainer alone doesn't trigger, only upon federal arrest	Clock starts at earliest February 1, more likely February 3
Was the indictment filed within 30 days?	Indictment was untimely under the Speedy Trial Act	Excluded days for pretrial motions made indictment timely	Indictment was timely; excluded days make 30 days max

United States v. Woolfolk, 399 F.3d 590 (4th Cir. 2005) (defines when federal speedy trial clock starts for federal restraint)
United States v. Thomas, 55 F.3d 144 (4th Cir. 1995) (clarifies federal restraint may precede formal federal arrest)
United States v. Lee, 818 F.2d 302 (4th Cir. 1987) (federal detainer alone is not an arrest to trigger Speedy Trial clock)
United States v. Wright, 990 F.2d 147 (4th Cir. 1993) (excludes certain days for pretrial motions from speedy trial calculation)