United States v. Tinklenberg
131 S. Ct. 2007
| SCOTUS | 2011Background
- Respondent Tinklenberg was convicted of felon in possession of a firearm and possession of items used to manufacture a controlled substance.
- Initial appearance occurred October 31, 2005, triggering the 70-day speedy-trial clock.
- Trial commenced August 14, 2006, amounting to 287 days from initial appearance.
- District Court counted 218 days excludable under Speedy Trial Act, leaving 69 nonexcludable days.
- Government sought three pretrial motions (Aug. 1–11, 2006) related to a video deposition, admissibility of seized firearms, and indictment dismissal; these were appealed by Sixth Circuit as not causally excluding time.
- Supreme Court reversed the Sixth Circuit on the causation requirement but affirmed the judgment on the alternate ground regarding a transportation-exclusion issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §3161(h)(1)(D) automatically excludes pretrial-motion time. | Government argues exclusion applies automatically upon filing of motion. | Tinklenberg argues exclusion depends on actual delay or expectation of delay. | Yes; automatic exclusion applies. |
| Whether weekend days and holidays are counted under §3161(h)(1)(F) transportation exclusion. | Government contends Rule 45(a) does not apply; weekends/holidays excluded only if justified. | Tinklenberg argues weekends/holidays should be counted as nonexcludable. | Weekends/holidays included in the 10-day transportation window. |
| Whether the Sixth Circuit’s approach would create administrative complexity and undermine the Act’s purpose. | Government emphasizes efficiency and uniform administration. | Tinklenberg argues the Sixth Circuit approach would hinder the Act’s automatic exclusions. | Court rejects Sixth Circuit approach as impractical; adopts automatic exclusions. |
Key Cases Cited
- Henderson v. United States, 476 U.S. 321 (1986) (automatic exclusion of certain pretrial-delay provisions)
- Bloate v. United States, 559 U.S. 196 (2010) (automatic applicability of enumerated delay exclusions)
- United States v. Wilson, 835 F.2d 1440 (CADC 1987) (automatic exclusions under §3161(h)(1) broadly recognized)