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United States v. Rickey Harris
Citations: 12 F.3d 735; 1994 U.S. App. LEXIS 115; 1994 WL 1948Docket: 93-1120
Court: Court of Appeals for the Seventh Circuit; January 5, 1994; Federal Appellate Court
The United States Court of Appeals for the Seventh Circuit ruled on the case of United States v. Rickey Harris, concerning whether Harris's confinement in disciplinary segregation constituted an 'arrest' under the Speedy Trial Act, which mandates that charges must be filed within thirty days of arrest. Harris, a federal prisoner, faced disciplinary action after refusing a urine sample, resulting in a 45-day solitary confinement and subsequent transfer delays. He asserted that his continued segregation after June 4, when his disciplinary term expired, amounted to an arrest, thus necessitating dismissal of the charges filed on August 10 for illegal possession of marijuana. The court clarified that the Speedy Trial Act does not define 'arrest' and expressed hesitation to broaden the term through analogy, especially in light of precedents that have not recognized similar claims under the Sixth Amendment. The judges distinguished between arrest and confinement, emphasizing that Harris was not arrested in the traditional sense, but rather remained in custody due to internal prison policies. The court noted that protections against unlawful confinement exist outside the Speedy Trial Act, such as under the Fourth and Fifth Amendments. Ultimately, the ruling affirmed that Harris had administrative remedies for his situation, but the Speedy Trial Act did not apply, leading to the affirmation of the district court's decision.