United States v. Smith
5:24-cr-00436
W.D. Okla.Jul 18, 2025Background
- Sixteen defendants, including Audrey Lassiter, were indicted for an alleged multi-state drug conspiracy violating 21 U.S.C. § 846.
- Lassiter was arraigned on May 21, 2025, and released on bond; most codefendants and the government sought trial continuances due to case complexity and discovery volume.
- Lassiter objected, filing motions for a speedy trial and to sever her case, citing her Sixth Amendment and statutory rights due to asserted prejudice from delay and differences between her charges and those of codefendants.
- The government and other defendants cited the complexity of the case and the need for adequate trial preparation as reasons to continue the trial into March 2026.
- The Court previously declared the case complex, deferred the trial date, and required government counsel to provide continuance order copies to unarraigned defendants.
Issues
| Issue | Lassiter's Argument | Government/Others' Argument | Held |
|---|---|---|---|
| Right to speedy trial | Trial delay causes undue prejudice (emotional/psychological harm); wants earliest trial date. | No Speedy Trial Act violation; not enough elapsed time since arraignment; complex case justifies delay. | Motion for speedy trial denied. |
| Severance from codefendants | Severance needed to avoid prejudicial delay and protect Confrontation Clause rights; distinct acts. | Joint trial preferred by law; no showing of specific prejudice; limiting instructions are sufficient. | Motion to sever denied (without prejudice to renew). |
| Continuance of trial | Opposed further delay due to speedy trial rights, limited involvement, and individual prejudice. | Supported for adequate preparation; case is multi-defendant and complex; public interest still served. | Continuance granted; trial reset to March 2026 docket. |
| Confrontation Clause | Joint trial risks incriminating statements from codefendants being used against her unfairly. | Lassiter offered only speculative risks; remedies exist for improper statements; not an issue yet. | No prejudice shown on current record. |
Key Cases Cited
- Zedner v. United States, 547 U.S. 489 (Speedy Trial Act provides for flexibility in complex cases)
- Barker v. Wingo, 407 U.S. 514 (Sixth Amendment speedy trial balancing test)
- Doggett v. United States, 505 U.S. 647 (Prejudice from delay can be relevant under the Sixth Amendment)
- United States v. Wardell, 591 F.3d 1279 (Tenth Circuit preference for joint trials of indicted codefendants)
- United States v. Zar, 790 F.3d 1036 (Strong presumption in favor of joint trials for codefendants)
- United States v. Margheim, 770 F.3d 1312 (Delay less than a year unlikely to violate Sixth Amendment)
- Bruton v. United States, 391 U.S. 123 (Confrontation Clause issues with codefendant statements at joint trial)
- United States v. McClure, 734 F.2d 484 (Conflicting defenses alone do not require severance)