United States of America v. Daniel E. Musso

2020 DNH 127
CourtDistrict Court, D. New Hampshire
DecidedJuly 20, 2020
Docket16-cr-33-JL
StatusPublished

This text of 2020 DNH 127 (United States of America v. Daniel E. Musso) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States of America v. Daniel E. Musso, 2020 DNH 127 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 16-cr-33-JL Opinion No. 2020 DNH 127 Daniel E. Musso

MEMORANDUM ORDER

Defendant Daniel E. Musso’s motion to dismiss the charges against him turns on

whether the period of delay between the initiation of those charges and his forthcoming

trial violates either the Speedy Trial Act, see 18 U.S.C. § 3161, or the right to a speedy

trial enshrined in the Sixth Amendment of the United States Constitution. Musso was

arrested in January 2016 and ultimately charged with four counts of receiving an

unregistered firearm and one count of receiving explosive materials in violation of

26 U.S.C. § 5861(d) and 18 U.S.C. § 842(a)(3)(A), respectively. His trial, originally

scheduled for May 2016, has been delayed by a series of his own requested continuances,

proceedings to establish his mental competency, a successful interlocutory appeal of this

court’s dismissal of the four counts of receiving an unregistered firearm, and the

COVID-19 pandemic.

The defendant agrees that much of this delay is excludable from the Speedy Trial

Act’s 70-day limit but argues that one or more of three periods are non-excludable,

causing the 4.5-year delay to violate that Act. As explained below, each of those three

periods is excludable under the Speedy Trial Act, so the Act has not been violated. And because the delay is justifiable, Musso has not been denied his right to a speedy trial as

guaranteed by the Sixth Amendment. His motion to dismiss the indictment is

accordingly denied.

Applicable legal standard

“In all criminal prosecutions, the accused shall enjoy the right to a speedy and

public trial . . . .” U.S. Const. amend. VI. Through the Speedy Trial Act, Congress has

“imposed specific time limitations on the district courts in order to make the Sixth

Amendment right to a speedy trial more effective.” United States v. Scott, 270 F.3d 30,

53 (1st Cir. 2001) (citations omitted). It “generally requires a trial to begin within 70

days of the filing of an information or indictment or the defendant’s initial appearance,”

though it also “includes a long and detailed list of periods of delay that are excluded in

computing the time within which trial must start.” Zedner v. United States, 547 U.S. 489,

497 (2006) (citing 18 U.S.C. § 3161).

Background

Musso was arrested on January 27, 2016 and indicted a month later on four counts

of receiving an unregistered firearm—specifically, grenades—in violation of 26 U.S.C.

§ 5861(d).1 He moved for pretrial release on March 28, 2016. The court rejected this

1 Indictment (doc. no. 12). A superseding indictment, filed in July 2017, added one count of receiving explosive materials in violation of 18 U.S.C. § 842(a)(3)(A). Superseding Indictment (doc. no. 47) at 5.

2 request.2 The parties agree that the 31 days between the indictment and Musso’s motion

for pretrial release are not excludable under the Speedy Trial Act.3

Though Musso’s trial was originally scheduled to begin on May 3, 2016, he

moved to continue that trial several times between April 12, 2016 and February 24,

2017.4 The court granted each motion, concluding that “the ends of justice served by a

continuance outweigh[ed] the best interest of the public and the defendant in a speedy

trial . . . for the reasons set forth in the motion.”5 And following each grant, Musso filed

an affirmative waiver of his speedy trial rights.6 Musso does not dispute that the periods

covered by these continuances are excludable under the Speedy Trial Act.7

Musso again moved successfully to continue his trial for 30 days on February 24,

2017.8 Had the court granted the motion on its own terms, that 30-day continuance

would have expired on April 7, 2017. Rather than scheduling a new trial date, however,

the court held a conference on March 21, 2017,9 during which Musso’s counsel raised

2 See Mot. for Bail (doc. no. 16); Order Denying Mot. for Bail (doc. no. 23). 3 See Gov’t Obj. (doc. no. 126) at 5 & n.2. 4 See Mots. to Continue Trial (doc. nos. 24, 27, 30, 33, 36). 5 Orders Granting Mots. to Continue Trial (doc. nos. 25, 28, 31, 34, 37). 6 Waivers of Speedy Trial (doc. nos. 26, 29, 32, 35, 38). 7 See Gov’t Obj. at 5 & n.2; Gov’t App’x 1 (doc. no. 126-1); Reply (doc. no. 127) (not disputing these characterizations). 8 Mot. to Continue Trial (doc. no. 39). 9 See Order Granting Mot. to Continue Trial (doc. no. 40) (directing clerk to schedule a conference); March 1, 2017 and March 13, 2017 Scheduling Notices.

3 competency issues with the court.10 Musso’s counsel subsequently filed a mental status

examination report.11 The court held another status conference on May 10, 2017, after

which it continued the trial “pending a determination of the issues concerning the

defendant’s mental status” and ordered Musso to undergo a psychiatric examination

pursuant to 18 U.S.C. §§ 4241 and 4242.12

Musso obtained new counsel and moved the court to reconsider that order. During

a hearing held on October 26, 2017, the court granted that motion, found Musso

competent to stand trial, and vacated its order requiring a psychiatric evaluation.13 It then

proposed a December 5, 2017 trial date.14 Though the prosecution represented that it was

prepared to try the case in December, Musso’s counsel requested additional time to

obtain and review discovery.15 Based on that request, the court set trial to begin on

January 9, 2018.16

10 Though it was held off the record, as explained infra Part III.A.2, evidence supports the conclusion that Musso’s counsel raised this issue during this conference. 11 Evaluation Report (doc. no. 41). 12 See Procedural Order of May 10, 2017 (doc. no. 44). 13 See Tr. of Oct. 26, 2017 Mot. Hr’g, Musso Ex. A (doc. no. 125-2) at 17–18. 14 Id. at 18. 15 Id. at 18, 20–21. 16 Id. at 22.

4 Musso moved on December 19, 2017 to continue that trial date,17 a motion to

which the prosecution objected in light of the increasing length of time between Musso’s

January 2016 arrest and his upcoming trial.18 The court granted Musso’s motion, finding

the continuance “appropriate in the interest of justice based on the circumstances of this

case.”19 Rather than continue the trial for only 30 days, however, the court rescheduled it

for April 3, 2018, to give Musso time to file, and the court time to resolve, his proposed

dispositive motion.20

As anticipated, Musso moved to dismiss the indictment. The court granted that

motion in part on March 9, 2018, dismissing Counts 1 through 4—those charging him

with receiving an unregistered firearm—on the grounds that the four grenades he

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2020 DNH 127, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-daniel-e-musso-nhd-2020.