Speedy Trial Act

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7^th Circuit Court of Appeals

Case Name: United States of America v. Linnel Blount, Jr.

Case No.: 22-2470

Officials: Easterbrook, Brennan, and Kirsch, Circuit Judges.

Focus: Speedy Trial Act

Linnel Blount, Jr. was convicted on drug and firearm charges in 2019 and sentenced to 63 months in prison. Blount’s jury trial, initially scheduled for February 2020, was postponed to March 2020 at his request. However, due to the COVID-19 pandemic, a series of court orders halted criminal jury trials from March 2020 through April 2021. The district judge further delayed Blount’s trial during this period, citing health and safety concerns. Eventually, Blount opted for a bench trial and waived his right to a jury, with proceedings beginning in July 2021.

Blount contended on appeal that his indictment should have been dismissed under the Speedy Trial Act because the trial delay was based on general pandemic-related court orders rather than specific circumstances in his case. However, the court of appeals determined that Blount’s attorney did not formally move to dismiss the indictment, a requirement under the Speedy Trial Act. Additionally, the court ruled that the district judge was not obligated to interpret Blount’s filings without explicit motions to dismiss.

Furthermore, the court held that the Speedy Trial Act does not mandate judges to reiterate considerations already established institutionally. It concluded that the delay of criminal jury trials during the COVID-19 pandemic was justified by societal, not individual, concerns, and therefore fell within the permissible bounds of the Speedy Trial Act.

Affirmed.

Decided 02/26/24

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