The Oyez Project: Criminal Procedure Issues - Timeliness

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.

Marvin Klehr purchased inadequate cattle feed containers from A. O. Smith Harvestore Products, Inc. (Harvestore) in 1974. Over a long period of time, the containers damaged Klehr's cattle feed. In 1993, Klehr filed a civil claim against Harvestore under the Racketeer Influenced and Corrupt Organizations Act of 1970 (RICO). The District Court dismissed Klehr's suit, ruling that the four-year time limit for bringing a civil RICO suit had expired. Klehr claimed that he was not at fault for failing to discover the injury within four years, because Harvestore purposely designed the containers to conceal their inadequacy.

The U.S. Court of Appeals for the Eighth Circuit upheld the lower court. The Eighth Circuit held that Klehr should have discovered the pattern of racketeering activity much earlier. Since the statute of limitations began from the time Klehr could reasonably be expected to have discovered the pattern, Klehr was out of time. The Eighth Circuit's "pattern of activity" rule contradicted the Third Circuit's "last predicate act" rule, which allows a plaintiff to recover damages accumulated since the first injury as long as the last RICO violation ("last predicate act") happened within four years of the lawsuit.

Moody v. Flowers

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New York v. Hill

The Interstate Agreement on Detainers (IAD) is a congressionally sanctioned interstate compact to establish procedures for resolution of one state's outstanding charges against a prisoner of another state. Under the Compact Clause, the IAD is a federal law subject to federal construction. In order to resolve outstanding murder and robbery charges against Michael Hill, an Ohio prisoner, the State of New York lodged a detainer against him under the IAD. Hill filed a request for disposition of the detainer, pursuant to IAD Article III, and was returned to New York. Article III provides that, upon such a request, that the prisoner be brought to trial within 180 days. Thereafter, Hill's counsel agreed to a trial date outside the 180-day period. Subsequently, Hill moved to dismiss his indictment, arguing that the IAD's time limit had expired. The trial court denied Hill's motion, concluding that his defense counsel's explicit agreement to the trial date constituted a waiver or abandonment of Hill's IAD rights. After his conviction and subsequent appeal, the Appellate Division of the New York Supreme Court affirmed the trial court's refusal to dismiss. In reversing, the state Court of Appeals ordered that Hill's indictment be dismissed because his counsel's agreement to a later trial date, it held, did not waive his IAD speedy trial rights.

North Star Steel Co. v. Thomas

The Worker Adjustment and Retraining Notification Act (WARN) authorizes a civil enforcement action by aggrieved employees or their union against a covered employer who fails to give 60 days notice of a plant closing or mass layoff, but provides no limitations period for such an action. In 94-835, the United Steelworkers of America filed a WARN claim, charging Crown Cork & Seal Co., Inc. with laying off 85 employees without giving the required 60-day notice. In rejecting Crown Cork's contention that the statute of limitations had run, the District Court held that the source of the limitations period for WARN suits is state law and that the union's suit was timely under any of the arguably applicable Pennsylvania statutes. In 94-834, another District Court granted summary judgment for North Star Steel Company, holding the nonunion employees' suit barred under a limitations period borrowed from the National Labor Relations Act, which the court believed was more analogous to WARN than any state law. The Court of Appeals consolidated the cases and held that a WARN limitations period should be borrowed from state, not federal, law.

Thomas v. Arn

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Thompson v. I. N. S.

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United States v. Alvarez-Sanchez

Three days after his arrest by local police on state narcotics charges, Pedro Alvarez-Sanchez confessed to the Secret Service that federal reserve notes found in his home were counterfeit. When he was subsequently charged with the federal offense of possession of counterfeit currency, Alvarez defended himself by claiming that the delay between his arrest on state charges and his presentment on the federal charge rendered his confession inadmissible. Alvarez cited 18 U.S.C. Section 3501(c), which pronounced separate charge-based confessions inadmissible if obtained after the first six hours of detention. On appeal from a reversal of a district court's decision to uphold the confession, the Supreme Court granted the United States certiorari.