United States v. Keith

61 F.4th 839
CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 7, 2023
Docket21-6158
StatusPublished
Cited by21 cases

This text of 61 F.4th 839 (United States v. Keith) 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. Keith, 61 F.4th 839 (10th Cir. 2023).

Opinion

Appellate Case: 21-6158 Document: 010110822697 Date Filed: 03/07/2023 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS March 7, 2023

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v. No. 21-6158

AARON KEITH, a/k/a AK, a/k/a Keke,

Defendant - Appellant. _________________________________

Appeal from the United States District Court for the Western District of Oklahoma (D.C. No. 5:18-CR-00260-SLP-45) _________________________________

Gail K. Johnson of Johnson & Klein, PLLC, Boulder, Colorado, for Defendant- Appellant.

Steven W. Creager, Assistant United States Attorney (Robert J. Troester, United States Attorney; David McCrary, Assistant United States Attorney; and Nick M. Coffey, Assistant United States Attorney, with him on the brief), Oklahoma City, Oklahoma, for Plaintiff-Appellee. _________________________________

Before MATHESON, KELLY, and PHILLIPS, Circuit Judges. _________________________________

PHILLIPS, Circuit Judge. _________________________________

In our legal system, criminal defendants have a right to a speedy trial—

they cannot languish in pretrial detention. The Sixth Amendment and the Appellate Case: 21-6158 Document: 010110822697 Date Filed: 03/07/2023 Page: 2

Speedy Trial Act (STA) say as much. But the onus is on defendants to “spot[]

violations of the [STA].” Zedner v. United States, 547 U.S. 489, 502 (2006)

(discussing 18 U.S.C. § 3162(a)(2)). After months of delay in his drug-

conspiracy prosecution, Aaron Keith unsuccessfully moved to dismiss the

indictment on speedy-trial grounds. After his motion was denied, a jury

convicted him of all charges. He now renews those speedy-trial arguments.

Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

BACKGROUND

I. Factual Background

Keith joined the Irish Mob Gang (IMG), a prison gang, while serving an

Oklahoma state sentence. Like many gangs, the IMG was in the drug trade.

From their prison cells, Keith and his IMG confederates coordinated large drug

transactions outside of prison. Using contraband cell phones, members acted as

intermediaries between drug suppliers and buyers on the outside. In November

2018, during its ongoing investigation into the IMG, the FBI wiretapped an

IMG leader’s cell phone. Many conversations recorded on the wiretap

implicated Keith in the gang’s drug dealing. Keith’s role in the conspiracy was

nearing its end.

II. Procedural Background

In October 2018, in the first of three indictments, a federal grand jury

charged 39 IMG members and affiliates with drug conspiracy and other drug

and money-laundering offenses. Keith wasn’t among the indicted defendants.

2 Appellate Case: 21-6158 Document: 010110822697 Date Filed: 03/07/2023 Page: 3

Given the conspiracy’s reach and the extensive discovery involved, the

government moved to declare the case complex and to continue the trial. The

district court granted the unopposed motion after finding under the STA that the

“ends of justice” outweighed the public’s and defendants’ interests in a speedy

trial. See 18 U.S.C. § 3161(h)(7)(A). In a separate scheduling order, the court

set trial for February 11, 2020.

On December 12, 2018, the grand jury returned a superseding indictment,

this time naming 55 defendants, including Keith. Keith was charged with drug

conspiracy and possessing methamphetamine with intent to distribute. He was

arraigned on December 19, at which time the STA clock began. According to

the prior scheduling order, each newly indicted defendant had two weeks after

being arraigned to object to the proposed schedule. “A failure to object,”

cautioned the court, “will be deemed a Defendant’s acknowledgment and

approval of [the complex-case designation] and the scheduling deadlines.”

Keith didn’t object, tacitly consenting to the February 2020 trial date.

A. Pretrial Delays

A year passed without incident. But on January 6, 2020, with only six

defendants remaining for trial, two of Keith’s codefendants moved to continue

the trial to August 2020. Citing their newly appointed counsels’ need to review

discovery and prepare for trial, the two defendants informed the court that

“[a]ll parties have conferred and are in agreement with this requested

continuance.” Suppl. R. at 678–79. Keith didn’t object, so the court made new

3 Appellate Case: 21-6158 Document: 010110822697 Date Filed: 03/07/2023 Page: 4

“ends-of-justice” findings and continued the trial to August 11, 2020. In

determining that the continuance wouldn’t prejudice the defendants, the court

mistakenly understood that Keith and the other defendants were serving state

sentences. But in fact, Keith had completed his state sentence two weeks earlier

and was seeking a federal detention hearing.

Though the parties didn’t know it yet, a global pandemic was looming.

Once COVID-19 made an August 2020 trial date uncertain, the government and

the four remaining defendants submitted a joint status report. There, the parties

detailed

(1) that the defendants would be ready for trial in August but wanted it to be conducted “as ‘normally’ as possible”; (2) that the U.S. Marshals Service might encounter problems serving defense subpoenas; (3) that there could be logistical challenges, such as the need for a Spanish-language interpreter for one defendant; (4) that COVID-19-related prison restrictions made it difficult for the government to prepare its several in-custody witnesses; (5) that the government proposed three separate trials to maintain proper social distancing, but that Keith and a codefendant objected to being tried separately; and (6) that the government didn’t think an August trial was possible.

A week after filing the status report, the government obtained a second

superseding indictment against seven defendants, including the four from the

status report. The second superseding indictment charged Keith with one count

of drug conspiracy in violation of 21 U.S.C. §§ 846, 841(a)(1), (b)(1)(A), and

one count of possessing methamphetamine with intent to distribute in violation

of § 841(a)(1), (b)(1)(A).

4 Appellate Case: 21-6158 Document: 010110822697 Date Filed: 03/07/2023 Page: 5

In July, the government moved to continue the trial from August to

November 2020, citing COVID-19’s effect on trial preparations and a need for

extra time for plea negotiations. The government advised the court that Keith

didn’t object to this continuance. Indeed, Keith had rejected the government’s

offer to be tried alone in August; the government reported that Keith “would

rather wait and be tried with” his codefendants. Agreeing with the government’s

proffered reasons and making another ends-of-justice finding, the court granted

the motion and reset trial for November 3, 2020. 1

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Cite This Page — Counsel Stack

Bluebook (online)
61 F.4th 839, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-keith-ca10-2023.