Monday, December 23, 2013

Henderson v. United States case brief

Henderson v. United States case brief summary
476 U.S. 321 (1986)

Defendants sought review of a decision of the United States Court of Appeals for the Ninth Circuit affirming their convictions arising out of manufacturing, possessing, and distributing controlled substances after holding that the Speedy Trial Act, 18 U.S.C.S. § 3161(h)(1)(7), excluded delays resulting from pretrial motions without qualification.

Agents arrested defendants after the agents discovered an illicit drug factory. Overlapping filings by defendants and the prosecution kept a suppression motion pending for four months. Nearly two years later, the trial court denied a motion to suppress. Both parties filed additional motions before the prosecution moved to set the case for trial. The trial court denied defendants' motion to reconsider denial of the motion to suppress, and set a trial date. A decision affirming defendants' convictions was affirmed.


  • On further review, the court held that the phrase "prompt disposition" was intended to prevent a district court from using Speedy Trial Act, 18 U.S.C.S. § 3161(h)(1)(F), to exclude time after a motion was taken under advisement when that time failed to qualify for exclusion under 18 U.S.C.S. § 3161(h)(1)(J). 
  • Time after a hearing had been held was excluded under 18 U.S.C.S. § 3161(h)(1)(F) where a trial court awaited additional filings from the parties that were needed for proper disposition of the motion. 
  • The time waiting for a decision on the motion to suppress was automatically excludable. 
  • The time waiting for the decision of the motion to reconsider was also excludable.

The court affirmed the convictions because the delays resulting from the various pretrial motions were excluded such that the trials were considered speedy under the statute.

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