United States v. Bailey-Snyder

Inmate Bailey-Snyder was moved to administrative segregation after federal corrections officers found a homemade shank on his person. He remained in the Special Handling Unit (SHU) pending investigation. Ten months later, Bailey-Snyder was indicted for possession of a prohibited object in prison. He filed several motions for extensions before moving to dismiss, citing his placement in isolation as the start of the speedy trial clock. The district court denied the motion. At trial, defense counsel cross-examined the officers who found the shank regarding incentive programs for recovering contraband. The government elicited that the programs do not reward individual contraband recoveries. Neither officer discussed the potential consequences of planting a shank. The defense rested without offering testimony or evidence. During summation, the prosecutor stated: “The defendant is guilty of his crime." The court concluded that the prosecutor expressed personal belief in the defendant’s guilt; the prosecutor had to make a corrected statement to the jury. In closing, the government argued: “[i]t’s conjecture to say that these correctional officers would put their jobs, their careers, their livelihoods on the line to possibly plant a shank on this defendant to maybe, maybe, have a little notch to get a promotion.” The defense unsuccessfully objected, claiming the government was “arguing a fact not in evidence.” Bailey-Snyder was sentenced to 30 months’ imprisonment, consecutive to his underlying sentence. The Third Circuit affirmed. An inmate’s placement in isolation, while under investigation for a new crime, does not trigger his right to a speedy trial under the Sixth Amendment or the Speedy Trial Act. There was no improper vouching or cumulative error in Bailey-Snyder’s trial. View "United States v. Bailey-Snyder" on Justia Law