United States v. Gutierrez

133 F.4th 999
CourtCourt of Appeals for the Tenth Circuit
DecidedApril 4, 2025
Docket23-2076
StatusPublished

This text of 133 F.4th 999 (United States v. Gutierrez) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Gutierrez, 133 F.4th 999 (10th Cir. 2025).

Opinion

Appellate Case: 23-2076 Document: 87-1 Date Filed: 04/04/2025 Page:FILED 1 United States Court of Appeals Tenth Circuit PUBLISH April 4, 2025 UNITED STATES COURT OF APPEALS Christopher M. Wolpert Clerk of Court FOR THE TENTH CIRCUIT _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 23-2076

LUIS GUTIERREZ,

Defendant - Appellant. _________________________________

Appeal from the United States District Court for the District of New Mexico (D.C. No. 1:20-CR-01570-JCH-1) _________________________________

Margaret Ann Katze, Federal Public Defender, Albuquerque, New Mexico (Violet N. D. Edelman, Assistant Federal Public Defender, Albuquerque, New Mexico, on the briefs), for Defendant-Appellant.

Tiffany L. Walters, Assistant United States Attorney (Alexander M.M. Uballez, United States Attorney, with her on the brief), District of New Mexico, Albuquerque, New Mexico, for Plaintiff-Appellee. _________________________________

Before TYMKOVICH, BALDOCK, and McHUGH, Circuit Judges. _________________________________

TYMKOVICH, Circuit Judge. _________________________________

The Sixth Amendment to the Constitution guarantees “the accused . . . the

right to a speedy and public trial.” Luis Gutierrez argues the federal government

violated that right because it waited about two years after his indictment before Appellate Case: 23-2076 Document: 87-1 Date Filed: 04/04/2025 Page: 2

proceeding with his federal case. The government responds its delay was due to a

parallel state prosecution of Gutierrez and obstacles caused by the COVID-19

pandemic. And regardless, the government contends, Gutierrez suffered no prejudice

from the delay.

Gutierrez argues the government’s pretrial delay deprived him of an argument

he could have made at sentencing, which in turn could have won him a shorter

sentence. But the Speedy Trial clause’s text and history show its protections are

limited to the preconviction phase of a case and does not apply to alleged harms that

occur after the defendant is found guilty. Thus, prejudice suffered at postconviction

sentencing, even if it resulted from pretrial delay, is not cognizable under the Sixth

Amendment’s Speedy Trial clause.

We AFFIRM.

I. Background

A. Gutierrez is Charged with Both State and Federal Crimes

Luis Gutierrez was arrested in May 2020, after New Mexico state officers

found a loaded, stolen pistol in his motel room. Officers were looking for Gutierrez

after receiving reports that he had fired several rounds outside his estranged wife’s

home on at least two separate occasions. He also had threatened to kill her multiple

times.

Gutierrez was charged with both federal and state crimes. His state

proceedings moved first, and in October 2021, he pleaded guilty to two counts of

aggravated assault with a deadly weapon against a household member. He was 2 Appellate Case: 23-2076 Document: 87-1 Date Filed: 04/04/2025 Page: 3

sentenced to two years of imprisonment, and he was ultimately released on May 5,

2022.

As for his federal charge, Gutierrez was indicted for being a felon in

possession of a firearm on August 11, 2020, while he was jailed in an Albuquerque

detention facility. Federal agents delivered the indictment and arrest warrant to the

facility, but jail officials never notified Gutierrez of the federal charge. In fact,

Gutierrez only learned about the federal charge the day he was released from state

custody.

And that is in part because nothing happened in his federal case after the

indictment, while Gutierrez was in state custody and his state proceedings were

ongoing. The lull, the government explains, was due to the COVID-19 pandemic.

When Gutierrez was indicted, which was in the summer of 2020, both federal and

state governments had declared a public health emergency because of COVID-19.

The U.S. Marshals Service in New Mexico had instructed the U.S. Attorney’s Office

not to file writs for federal defendants in state custody from May 2020 to early March

2022. As a result, the federal government had no choice but to put Gutierrez’s case

on ice.

Eventually, federal officials took custody of Gutierrez on May 5, 2022—one

day after he completed his state sentence. His federal case then moved swiftly.

Three days after he completed his state sentence, Gutierrez was appointed counsel for

his federal case, made an initial appearance, and his arraignment and detention

hearing was held on May 11, 2022. That same day, his trial was set for July 18,

3 Appellate Case: 23-2076 Document: 87-1 Date Filed: 04/04/2025 Page: 4

2022. Soon after, on May 30, 2022, Gutierrez moved to continue his trial for

60 days. The district court granted the motion and reset the trial for September 19,

But with about a month left before the trial date, Gutierrez moved to dismiss

his indictment for violation of his speedy trial right under the Sixth Amendment. The

relevant delay period was about two years, starting from August 2020, when he was

federally indicted, to the date of his scheduled trial.

B. District Court Denies Gutierrez’s Sixth Amendment Claim, and Gutierrez Pleads Guilty

Applying the multi-factor test in Barker v. Wingo, 307 U.S. 514 (1972), the

district court denied Gutierrez’s motion to dismiss. The district court found that the

delay in the federal case was justified because of complications caused by the

pandemic, and Gutierrez failed to show any prejudice caused by the delay. To be

sure, Gutierrez argued the government’s failure to prosecute his case swiftly (while

he was serving his state sentence) caused him to forfeit an argument he could have

made at sentencing under U.S.S.G. § 5G1.3, which he claims would have resulted in

a lower guideline range, and in turn, a lower sentence. 1 But the district court was

unpersuaded, rejecting the argument that sentencing issues can count as prejudice

under the Speedy Trial clause, and finding the court can (and in fact, later did)

Section 5G1.3(b) states if “a term of imprisonment resulted from another 1

offense that is relevant conduct to the instant offense of conviction,” the court must “adjust the sentence” for the “instant offense” and allow it to “run concurrently to the remainder of the undischarged term of imprisonment.” 4 Appellate Case: 23-2076 Document: 87-1 Date Filed: 04/04/2025 Page: 5

modify the sentence on the back end to credit Gutierrez’s time in state prison, if he

was found guilty. Because Gutierrez failed to show he suffered any prejudice, the

court denied the motion to dismiss.

Two weeks after the district court denied his speedy trial claim, Gutierrez

pleaded guilty. As part of his plea agreement, he agreed to waive his right to appeal

his “conviction and sentence,” including the “manner in which the sentence [i]s

determined or imposed.” R., Vol. I. at 123–24. He retained the right to appeal the

district court’s denial of his Sixth Amendment claim. Id. at 124.

C. District Court Applies Upward Departure to Gutierrez’s Sentence and Credits His Time Served in State Prison

The district court determined a guideline range of 37–46 months applied to

Gutierrez. The court then found an upward departure was warranted under U.S.S.G.

§ 5K2.6, which allows for a “substantial sentence increase” if there is a “discharge of

a firearm” in the commission of the offense.

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Bluebook (online)
133 F.4th 999, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-gutierrez-ca10-2025.