Chase Russell Downey v. United States

The Court has made clear that the district courts have wide discretion to manage their dockets and case load, to schedule trials, and grant or deny continuances. Morris v. Slappy, 461 U.S. 1, 11, 103 S. Ct. 1610 (1983). But a denial of a request for more time to defend a case can violate the Fifth Amendment rights to due process and the Sixth Amendment right to counsel. Ungar v. Sarafite, 376 U.S. 575, 589, 84 S. Ct. 841 (1964); Avery v. Alabama, 308 U.S. 444, 446, 60 S. Ct. 321 (1940). The Court’s precedent establishes that both defendants and the public have an interest in a speedy trial. See Barker v. Wingo, 407 U.S. 514, 519, 92 S. Ct. 2182 (1972). But the Court is equally clear that both defendants and the public have an interest in a system that is fair and reliable, which must often come at the expense of haste. Vermont v. Brillon, 556 U.S. 81, 89, 129 S. Ct. 1283 (2009); Beavers v. Haubert, 198 U.S. 77, 86, 25 S. Ct. 573 (1905). In short, reliability and fairness are more important than the efficiency of a District Court’s docket. In this case, the District Court gave Petitioner a notice allowing him only 15 days to file pretrial motions. Petitioner’s first counsel filed no pretrial motions in that time. The District Court appointed Petitioner new counsel. Thus, new counsel entered the case after the District Court’s period for filing pretrial motions had already expired. Despite several motions for continuances from both parties, at no time did the District Court allow any additional time for defense motions to be filed. The Government took substantial time to provide new counsel with the discovery that showed grounds for a fourth amendment challenge. But with the pretrial motion already in the rearview mirror, new counsel focused on attempting to resolve the matter through plea negotiations. Only once the plea negotiations surprisingly broke down did Petitioner’s new counsel file a motion for continuance and motion for leave to file a single suppression motion based on a viable fourth amendment challenge. The circuit majority recognized and listed several of Petitioner’s grounds for seeking leave to file a suppression motion. Nevertheless, the Majority blamed appellate counsel for failing to develop an argument that Petitioner had good cause to file an untimely motion. Pet. App. 8. The Majority reached the merits anyway, putting on blinders to ignore all other factors, and distilling Petitioner’ several good causes down to one—that second counsel “consciously decided” to not file a pretrial motion by the deadline in an attempt to curry favor with the prosecution in plea negotiations.” Pet. App. 8. But no attorney for Petitioner consciously decided against filing a motion by any deadline. First counsel had just 15 days. The District Court refused to extend that deadline. The District Court appointed second counsel after the deadline passed. Moreover, here in a system of pleas, rather than trials, the District Court ruling discourages plea negotiation and invites the filing of needless pretrial motions. The questions for the Court are whether, under these circumstances, the District Court erred in refusing to grant a continuance of trial and leave to file a single suppression motion and whether the Sixth Circuit Majority erred in affirming that decision.