In United States v. Layfield, --- F.4th ---, No. 22-50047 (9th Cir. 2024), the Court affirmed Philip James Layfield’s convictions for wire fraud, mail fraud, and various tax offenses.
Layfiend argued that the twenty-one days it took the U.S. Marshals Service to transport him from the District of New Jersey (where agents arrested him) to the Central District of California (where the grand jury indicted him) should have triggered a Speedy Trial Act violation.
The Court rejected his argument. It explained, Section 3161(c)(1) provides that the seventy-day STA clock is triggered only by the public filing of the indictment or the first appearance before a judge of the court in which the charge is pending, whichever date last occurs. Thus, the twenty-one-day delay between Layfield’s detention in New Jersey and his first appearance before a judge in the CDCA was immaterial to the Speedy Trial Act analysis.
