Zedner v. United States
In 2003, Jacob Zedner was convicted in federal court of six counts of attempting to defraud a financial institution, crimes for which he was indicted in 1996. Zedner appealed his conviction based on the Speedy Trial Act, which provides a defendant's trial must commence within seventy days from the date he is indicted. Failure to meet this deadline requires direct dismissal of the indictment, unless the delays are "excluded" by the trial court. The Act gives a specific list of excused delays.
After Zedner was indicted, a series of delays ensued, all of which the trial court excluded under the Speedy Trial Act. On November 8, 1996, Zedner requested the case be adjourned until the end of January, 1997. Because of the court's full docket and because of concern that Zedner would invoke his rights under the Speedy Trial Act, the court conditioned adjournment on Zedner's waiving his speedy trial rights "for all time." After this waiver, the court issued no more orders to exclude any delays. Over the next few years, more delays ensued, including a psychological evaluation for Zedner's fitness to stand trial and his brief commitment to a mental hospital. The court did not enter any orders to exclude these delays, presumably because of Zedner's waiver of rights.
On appeal, Zedner claimed that the district court violated his rights under the Speedy Trial Act, relying on a case holding that a defendant's waiver of his rights under the Act is invalid if it would violate the public's interest in the prompt prosecution of criminal indictments. The Second Circuit Court of Appeals rejected Zedner's argument, noting that the delays Zedner complained of were caused partly by his own behavior or granted at his request. The court reasoned that the public interest in speedy trials is not advanced by allowing a defendant to protest delays that were granted at his request. Further, it found that the district court's failure to enter an order specifying that the trial was delayed during the time of Zedner's incompetence to stand trial was at most a technical violation of the statute, and one that did not prejudice Zedner's rights. The court affirmed Zedner's conviction.
Questions Presented:
1. Whether, in light of the statute's text and Congress's goal of protecting the public interest in prompt criminal trials, the requirements of the Speedy Trial Act may be waived only in the
limited circumstances mentioned in the statute, the issue left open in New York v. Hill, 528 U.S. 110, 117 n.2 (2000).
2. Whether a violation of the Speedy Trial Act's 70-day time limit for bringing a defendant to trial is subject to harmless error analysis, despite the statute's mandatory language stating that, in
the event of a violation, the "indictment shall be dismissed."
