Jacob Zedner v. United States (547 U.S. 489)
U.S. Supreme Court · decided June 5, 2006 · Supreme Court Database (Spaeth)
- Citation
- 547 U.S. 489 · 126 S. Ct. 1976
- Decided
- June 5, 2006
- Term
- October Term 2005
- Vote
- 9–0
- Majority author
- Justice Alito
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Alito delivered the opinion of the Court. This case requires us to consider the application of the doctrines of waiver, judicial estoppel, and harmless error to a violation of the Speedy Trial Act of 1974 (Speedy Trial Act or Act), 18 U. S. C. §§ 3161-3174. The Act generally requires a federal criminal trial to begin within 70 days after a defendant is charged or makes an initial appearance, § 3161(c)(1), but the Act contains a detailed scheme under which certain specified periods of delay are not counted. In this case, petitioner’s trial did not begin within 70 days of indictment. Indeed, his trial did not commence until more than seven years after the filing of the indictment, but petitioner, at the suggestion of the trial judge, signed a blanket, prospective waiver of his rights under the Act. We address the following questions: whether this waiver was effective; whether petitioner is judicially estopped from challenging the validity of the waiver; and whether the trial judge’s failure to make the findings required to exclude a period of delay under a particular provision of the Act, § 3161(h)(8), was harmless error. I In March 1996, petitioner attempted to open accounts at seven financial institutions using counterfeit $10 million United States bonds. The quality of the counterfeiting was, to put it mildly, not expert. One bond purported to be issued by the…
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