United States v. Parker

District Court, District of Columbia·Decided May 20, 2026·No. Criminal No. 2025-0096·Published

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Crim. A. No. 25-96 (JDB)

DEVONTEE PARKER

MEMORANDUM OPINION & ORDER

Devontee Parker, accused of several sex trafficking offenses, seeks reconsideration of this

Court’s decision to continue his trial and toll the Speedy Trial Act for the ends of justice. The

Court continued trial from March 31, 2026, to September 8, 2026, and excluded the intervening

time from Speedy Trial calculation after finding that proceeding to trial could result in a

miscarriage of justice and that the volume of unreviewed discovery made timely and effective

preparation impossible. Parker objected to that decision at the time and reiterates his contentions

now. However, because Parker raises arguments that the Court has already considered and does

not otherwise provide a basis for revisiting the Court’s determinations, reconsideration is denied.

LEGAL STANDARD

The Federal Rules of Criminal Procedure do not expressly provide for motions for

reconsideration. Nevertheless, courts in this district have determined that motions for

reconsideration may be entertained in criminal cases and have adopted the same standards that

apply to such motions filed in civil cases pursuant to Rule 59(e) of the Federal Rules of Civil

Procedure. See United States v. Sunia, 643 F. Supp. 2d 51, 60 (D.D.C. 2009); United States v.

Booker, 613 F. Supp. 2d 32, 34 (D.D.C. 2009). “A Rule 59(e) motion is discretionary and need not be granted unless the district court finds that there is an intervening change of controlling law,

the availability of new evidence, or the need to correct a clear error or prevent manifest injustice.”

Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996).

ANALYSIS

The Speedy Trial Act provides that trial shall commence within seventy days after the

defendant appears in front of a judicial officer of the district court where charges are pending. 18

U.S.C. § 3161(c). That clock may be paused if a statutory exception applies, including when the

court finds that “the ends of justice served by taking such action outweigh the best interest of the

public and the defendant in a speedy trial.” Id. § 3161(h)(7)(A). In making such a determination,

the court must explain its reasoning, weighing the following factors: (i) whether proceeding to trial

could result in a miscarriage of justice, (ii) whether the complexity of the case makes adequate

preparation unreasonable, (iii) whether the complexity of the indictment delayed the grand jury’s

decisions, and (iv) whether failure to grant a continuance would deny counsel the reasonable time

necessary for effective preparation. Id. § 3161(h)(7)(B). “The substantive balancing underlying

the decision to grant [an ends of justice] continuance is entrusted to the district court’s sound

discretion.” United States v. Rice, 746 F.3d 1074, 1078 (D.C. Cir. 2014). And because the Speedy

Trial Act protects the public’s interest in a fair trial as well as the accused’s interest in a timely one,

courts may grant continuances over the objections of the defendant. See United States v. Reid,

Crim. A. No. 21-174, 2021 WL 11709775, at *1 (S.D.N.Y. June 17, 2021) (collecting cases where

the Speedy Trial Act is tolled over the defendant’s objection and noting that “[t]he ends-of-justice

determination is . . . entrusted to the court, not the parties”).

At the status hearing on March 13, 2026, this Court determined that the above factors

weighed in favor of continuance. The Court concluded that proceeding to trial risked a miscarriage

2 of justice. Tr. [ECF No. 73] at 25:4-26:9. As an initial matter, Parker had been unable to review

more than a small fraction of the discovery he had requested, and he previously represented that

this discovery contained exculpatory material or was otherwise essential to his defense. Some of

that material had been lost in the mail and was only newly available to him, and he faced difficulties

getting regular access to a laptop.1 Additionally, Parker’s standby counsel had recently withdrawn

from the case, and his new standby counsel represented that she would be unable to meaningfully

assist Parker for trial by the end of March. The Court also concluded that Parker would be unable

to consider and discuss aspects of pretrial preparation and trial strategy before the end of the month.

With all that considered, the Court concluded that proceeding to trial on March 31 risked gross

unfairness and a potential miscarriage of justice.

The Court next considered the complexity of the case. The Court concluded that, although

the charges were not especially novel, “discovery has made [the case] somewhat complex,”

especially because a substantial portion of discoverable material was made available to Parker only

after the discovery deadline had passed. Tr. at 26:7-26:21. Moreover, the charged conduct took

place over several years and across multiple jurisdictions across the country, and the case involves

physical evidence, multiple cell phone extractions, location data, state police records, financial

records and other electronic information. Indeed, Parker has requested that the Government

acquire evidence for him from several different jurisdictions. The Government also plans on

calling multiple experts to testify, and Parker has sought the assistance of two specialists. And this

case presents difficult issues related to “the presentation and cross-examination of witnesses”

because of Rule 412 of the Federal Rules of Evidence, which limits the admissibility of evidence

1 To ensure that this would not be an issue prospectively, the Court arranged with the U.S. Marshals Service to allow Parker to come to the courthouse and review discovery with his standby counsel.

3 related to a witness’s prior sexual conduct. Tr. at 26:13-17. As the Court explained in its February

20, 2026, memorandum opinion, Rule 412 limits Parker’s ability to ask certain questions, but

Parker may move to admit certain evidence under Rule 412(c) during trial if he believes it is

necessary to vindicate his rights under the Confrontation Clause. Feb. 20 Mem. Op. [ECF No. 60]

at 7 n.4. Parker has previously suggested that Rule 412 evidence is crucial to his defense, and any

motions to admit such evidence would need to be filed before trial, unless the need for specific

Rule 412 evidence is unforeseeable until it arises at trial. Together, these factors demonstrate

complexity sufficient to render preparation by the anticipated trial date—a mere 18 days after the

status conference—unreasonable.

And finally, the Court concluded that proceeding to trial would impede Parker’s effective

preparation. Tr. at 26:22-27:3. For the same reasons as explained above, the Court found the

scheduled trial date would not allow Parker the reasonable time necessary for effective

presentation and preparation of his defense.

Parker’s motion for reconsideration does not raise previously unavailable evidence or new

law as required to alter the Court’s decision. To the contrary, Parker largely argues that his ability

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Related

§ 3161
18 U.S.C. § 3161
§ 4086
18 U.S.C. § 4086