United States v. Saul Frederick, 18-15310

2012 federal indictment charged Saul Frederick and others in a tax-return fraud/identity-theft scheme; by indictment Frederick had moved to Haiti and remained abroad until arrested in July 2018.
Frederick was placed on fugitive status in November 2012; the U.S. Marshals Service did not act until mid-2018, while IRS Special Agent Skinner led much of the investigation.
Investigative efforts (2012–2018) included interviews of codefendants, family, and associates; searches of databases and social media; obtaining phone, travel, and wage records; attempted passport revocation (2015); and an Interpol Red Notice (2016).
New lead in June 2018 identified Frederick’s employment and hometown in Haiti; Marshals coordinated with Haitian authorities and arrested him July 17, 2018.
Frederick moved to dismiss the indictment for Sixth Amendment speedy-trial violation based on nearly six-year delay between indictment and arrest; district court held an evidentiary hearing and denied the motion.
Frederick pleaded guilty (reserving the speedy-trial claim), was sentenced to 61 months, and appealed; the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether length of delay triggers Barker analysis	Nearly six-year post-indictment delay is presumptively prejudicial	Length alone is not dispositive without other Barker factors	Court assumed delay triggered inquiry but demanded analysis of other factors
Whether government’s reason for delay justified	Government failed to diligently pursue Frederick abroad; limited U.S.-focused efforts and delayed Marshal involvement	Government acted in good faith: interviews, records checks, passport revocation attempt, Interpol Red Notice, periodic database checks	Delay was not due to bad faith; government showed "some diligence"; negligence was slight and weighed only minimally against government
Whether Frederick promptly asserted speedy-trial right	Frederick relied on presumption of prejudice despite delayed assertion	Frederick knew of charges by March 2017 but did not assert right until Aug 2018; delayed assertion undermines claim	Failure to promptly assert right meant this factor did not weigh heavily for Frederick
Whether defendant suffered actual prejudice	Presumptive prejudice from long delay suffices	Frederick stipulated he could not prove actual, particularized prejudice	No actual prejudice proven; absent heavy weight on other factors, dismissal unwarranted

Barker v. Wingo, 407 U.S. 514 (1972) (articulates four-factor speedy-trial balancing test)
Doggett v. United States, 505 U.S. 647 (1992) (presumptive prejudice from lengthy post‑indictment delay; need to weigh other Barker factors)
United States v. Oliva, 909 F.3d 1292 (11th Cir. 2018) (guidance on weighting negligence vs bad faith and delay analysis)
United States v. Villarreal, 613 F.3d 1344 (11th Cir. 2010) (standards of review for mixed question of law and fact)
United States v. Ingram, 446 F.3d 1332 (11th Cir. 2006) (application of Barker factors)
United States v. Bagga, 782 F.2d 1541 (11th Cir. 1986) (government must make diligent, good-faith effort to locate fugitive; mere negligence may not require dismissal)
United States v. Machado, 886 F.3d 1070 (11th Cir. 2018) (government efforts to locate defendant abroad can be sufficient; exhaustion of all avenues not required)