Aleksandr Pikus v. United States

The Speedy Trial Act establishes bright-line deadlines to enforce the Sixth Amendment’s speedy trial guarantee. When violations occur, courts may dismiss with or without prejudice. 18 U.S.C. § 3162(a)(2). Critically, appellate review “must serve to ensure that the purposes of the Act and the legislative compromise it reflects are given effect.” United States v. Taylor, 487 U.S. 326, 336 (1988). This case exemplifies the precise breakdown in speedy trial protections that appellate review was designed to prevent. After the government’s discovery failures produced two separate Speedy Trial Act violations, the Second Circuit reversed, finding “extraordinary delays” caused by the prosecution’s “dilatory conduct” and judicial failure to hold the government accountable. App. 66a. Yet on remand, the same district court rejected these appellate findings, permitted reprosecution, and ignored Taylor’s precedent on presumptive prejudice. When a different Second Circuit panel affirmed this departure from controlling law, it effectively abandoned Taylor’s directive that appellate review must protect the Act’s legislative purpose. The Question Presented is: Whether this Court should exercise its supervisory power to correct the Second Circuit’s failure “to ensure that the purposes of the [Speedy Trial] Act and the legislative compromise it reflects are given effect” when it affirmed a district court’s departure from: (1) this Court’s precedent in Taylor establishing presumptive prejudice from extraordinary delays; and (2) the appellate court’s own factual findings regarding governmental and judicial neglect.