A MANUAL OF JURY TRIAL PROCEDURES - 2004
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Chapter One: Pre-Trial Considerations

1.4     Other Delays

While some short postponements have been tolerated, the following lengthier delays have been found to violate due process: Cf. United States v. Hay, 122 F.3d 1233, 1235 (9th Cir. 1997) (48-day delay between close of evidence and closing arguments held to have violated defendant's due process rights). United States v. Stayton, 791 F.2d 17 (2d Cir. 1986) (23 months); United States v. Andrews, 790 F.2d 803 (10th Cir. 1986) (two and one-half months), cert. denied, 481 U.S. 1018 (1987); United States v. Fox, 788 F.2d 905 (2d Cir. 1986) (five and one-half months).