The Oyez Project: Criminal Procedure Issues - Timeliness Decisions

Agency Holding Corp. v. Malley-Duff & Assocs.

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Honda v. Clark

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Houston v. Lack

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Klehr Et Ux. v. A. O. Smith Corp.

1)Does the time limit for filing a civil claim under the Racketeer Influenced and Corrupt Organizations Act of 1970 (RICO) begin after the plaintiff discovers the last illegal act ("last predicate act") at the end of a pattern of racketeering activity?

2)If the plaintiff demonstrates "fraudulent concealment" of the injury inflicted, can RICO's civil-claim limitations period be extended?

No and No. Justice Stephen Breyer wrote the opinion for a unanimous Court. The "last predicate rule...lengthens the limitations period dramatically" and thereby contradicts Congress's intention of ensuring a time limit for civil RICO claims. Also, "the plaintiff cannot use an independent, new act as a bootstrap to recover for injuries caused by other predicate acts that took place outside the limitations period."

RICO intends "not only to compensate victims but also to encourage those victims diligently to investigate and thereby to uncover unlawful activity." To demonstrate "fraudulent concealment", a plaintiff must have failed to discover injuries inflicted upon him after acting with "reasonable diligence" to discover the source and pattern of the injuries.

Moody v. Flowers

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New York v. Hill

Does a defense counsel's agreement to a trial date outside the 180-day time period required by Article III of the Interstate Agreement on Detainers waive the defendant's right to a speedy trial?

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that a defense counsel's agreement to a trial date outside the period provided for by the IAD bars the defendant from seeking dismissal on the ground that trial did not occur within that period. Noting scheduling matters are generally controlled by counsel without the fully informed and publicly acknowledged consent of the client, Justice Scalia wrote, "[w]hat suffices for waiver depends on the nature of the right at issue." In such cases, "[a]bsent a demonstration of ineffectiveness, counsel's word on such matters is the last." Thus, defense counsel's agreement to a later trial date waived Hill's speedy trial rights under the IAD.

North Star Steel Co. v. Thomas

Is state law the proper source of the limitations period for civil actions brought to enforce the Worker Adjustment and Retraining Notification Act?

Yes. In a 9-0 opinion delivered by Justice David H. Souter, the Court held that State law is the proper source of the limitations period for civil actions brought to enforce WARN. Where a federal statute fails to provide any limitations period for a new cause of action, the Court noted that its longstanding practice has been to borrow the limitations period from the most closely analogous state statute. The Court reasoned that North Star did not fall within the exception where the relevant state limitations periods would frustrate or interfere with the implementation of national policies or be at odds with the purpose or operation of federal substantive law. Justice Antonin Scalia concurred in the judgment.

Thomas v. Arn

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Thompson v. I. N. S.

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United States v. Alvarez-Sanchez

Does federal statute 18 U.S.C. Section 3501(c), declaring separate charge-based confessions inadmissible if obtained after the first six hours of detention, apply to suspects that are held only on state or federal charges?

No. In a unanimous decision, the Court held that the provisions of the federal statute in question do not apply to suspects being held solely on state charges. The Court explained that no delay is said to occur until the suspect is arrested and detained for a federal crime. The six-hour period only begins to expire from the point of a suspect's federal arrest and charging. In this case, Alvarez-Sanchez was presented before a federal judge within six hours of his arrest on a federal counterfeit charge. The fact that he was held for some two and a half days prior has no bearing on his federal status under the statute since he was detained on state and local charges only during this time.