Circuit Blotter: United States v. Maryea, No. 11-2239, 2013 WL 150316 (1st Cir. Jan. 15, 2013)
In Maryea, the First Circuit grappled with role of the courts in enforcing the Speedy Trial Act. Defendant Lynette Maryea was convicted of one count of conspiracy to possess Oxycontin, Suboxone, Lorazepam, and Ativan with intent to distribute. Maryea participated in a scheme to smuggle the painkillers to her boyfriend inside a New Hampshire correctional facility. Maryea purchased the drugs by filling forged prescriptions, then delivered the drugs in latex gloves to “trustees working within the laundry department” at a nursing home located next to the jail.
Maryea had spent time in a psychiatric facility for the treatment of a bipolar disorder, and complained at trial of back and neck pain requiring medication. A codefendant requested a continuance to resolve a related state law case, which the District Court granted. Maryea opposed severance, but moved for dismissal on the basis of a violation of the Speedy Trial Act, which guarantees that a defendant will have a trial to determine guilt within a particular period of time, while excepting particular delays from the calculation, including delays requested by a codefendant. The District Court denied Maryea’s motions for dismissal. During trial, Maryea was injured in a car accident. The court ordered an independent medical evaluation to ascertain injuries and whether the “continuing effects of those injuries, if any, will prevent her from meaningfully participating in the ongoing criminal trial and assisting with her defense.”
Maryea made two principal arguments on appeal. First, she argued that the reasonableness of the continuances should be judged with respect to her (as opposed to her codefendant) for Speedy Trial Act purposes, and the continuances at issue should have been determined to be unreasonable. Second, she argued that the district court should have explicitly ordered a psychiatric evaluation.
The First Circuit rejected both arguments. Assuming, without deciding, that the “Codefendant Clause” of the Speedy Trial Act (which permits “a reasonable period of delay” at the request of one co-defendant) was subject to a reasonableness limitation, it found the delays requested by the Maryea’s co-defendant reasonable because Maryea did not petition for (or indeed want) severance, and the reasons for joint trial in this case were compelling, since the codefendants were charged with perpetrating a single conspiracy.
The court noted that a judge must inquire into a defendant’s mental capacity to stand trial if “there is reasonable cause to believe a defendant may presently be suffering from a mental disease or defect rendering him mentally incompetent . . .” and that a new determination may be necessary when there is a “significant change of circumstances.” The First Circuit found those requirements satisfied by the competency evaluation conducted at the beginning of trial and the medical examination and court questioning after the accident.