Angel Landa-Arevalo v. United States
DueProcess JusticiabilityDoctri
Was Petitioner's right to a speedy trial violated under the Sixth Amendment and should the trial judge have ordered a mental health evaluation given the government psychologist's testimony?
QUESTIONS PRESENTED. Petitioner was first arraigned on three counts in a multidefendant drug distribution conspiracy on February 23, 2016. Trial did not commence until June 3, 2019. Petitioner did not oppose a motion to declare the case complex and to continue the case until May 8, 2017. His review of discovery resulted in the dismissal of one use of a communication facility count against him based on the government’s misidentification of the caller. When co-defendants, however, on April 10, 2017 sought to extend the trial beyond May, 2017, Petitioner objected, declaring he would not “waive his speedy trial right.” On May 9, 2017, fourteen months after his arraignment, a minimal period found to be presumptively prejudicial by the Tenth Circuit Court, Petitioner sought severance from his co-defendants and noted that “previous waivers under the Sixth Amendment had expired.” In hearings held June 6, 2017, July 24, 2018, and September 20, 2017, he opposed continuance requests by others and reiterated his right to a speedy trial. On July 26, 2018, Petitioner’s counsel renewed the motion to sever and “pursue his request for a speedy trial.” On August 9, 2018, Petitioner’s counsel again opposed a co-defendant’s motion for a continuance. All of Petitioner’s requests for protection under the Sixth Amendment’s Speedy Trial Clause were denied, as the trial court culled all the other defendants from the case. Petitioner’s trial did not commence until 39 months after his initial appearance, during which time Petitioner remained detained. The government’s own psychologist from the Bureau of Prisons testified that Petitioner had an unresolved adjustment disorder that became aggravated by lack of medication through his prolonged detention and further expressed a need for an extended mental health examination to evaluate whether a traumatic head injury several years before his arrest and bizarre acts of perseveration that caused him to focus on irrelevant details and a breakup of communication with his trial counsel indicated a more severe form of mental illness. Was Petitioner’s right to a speedy trial violated under the Sixth Amendment? Should the trial judge have ordered a mental health evaluation when urged to do so by both government and defense counsel who argued a bona fide doubt had been raised about Petitioner’s competency to stand trial?