Marijuana Convict Walks a Decade Early After Second Circuit Steps In
The defendant Joseph Tigano III, convicted in 2015 of operating a marijuana farm and sentenced to 20 years, was released Wednesday night from federal prison after the U.S. Court of Appeals for the Second Circuit issued a terse order on Wednesday afternoon dismissing the indictment against him.
November 16, 2017 at 06:56 PM
26 minute read
A criminal defendant who waited seven long years for his trial has been released from prison a decade early.
An overloaded calendar in the U.S. District Court for the Western District of New York. Prolonged competency evaluations of the defendant. Use of multiple magistrate judges. Delayed plea negotiations with prosecutors. A court reporter taking four months to prepare a transcript covering a daylong hearing. These were some of the issues allegedly experienced by Joseph Tigano III, who was convicted in 2015 of operating a marijuana farm and sentenced to 20 years, but who was released Wednesday night from federal prison after the U.S. Court of Appeals for the Second Circuit issued a terse order dismissing the indictment against him.
A full opinion from the Second Circuit panel is forthcoming. But oral arguments in the case, extensive briefing and the “with prejudice” dismissal of all charges against Tigano indicate that the panel found his Sixth Amendment constitutional right to a speedy trial was violated.
Whether the panel's opinion cites that as the precise reason for its ruling or not, the result of its order issued Wednesday is clear: Tigano, 53, walks from prison a free man more than a decade before his mandatory minimum sentence of 20 years was set to end. In the federal system, while defendants can win early release, most serve all or nearly all of their sentences.
According to court documents, Tigano was arrested by Drug Enforcement Administration agents at his home near Buffalo, in Chautauqua County, in July 2008.
His five-day trial didn't happen until May 2015.
In all, he spent more than seven years behind bars during the pretrial process, and another two years in prison after his conviction. On Wednesday night at about 11:30, he left Schuylkill federal correctional institution in Pennsylvania and walked into the arms of waiting family members, according to lawyers.
Tigano's pro bono attorneys at Schulte Roth & Zabel in Manhattan had argued that many factors—from unnecessary competency evaluations to crisscrossing magistrate judges—had contributed to the government negligently delaying his trial for years. They claimed the government's multitude of misplaced actions and fixable problems led to at least four years of unnecessary pretrial waiting. But the attorneys first grounded their arguments and briefing in a disturbing picture of a Western District of New York court system that, as they tell it, seemed to chug to a standstill.
“The record in this case can only properly be understood in the context of the caseload crisis that gripped the Western District of New York during the period of Tigano's prosecution,” wrote Gary Stein, a litigation partner at Schulte Roth, and Andrew Gladstein, a Schulte Roth associate on the case, in their brief filed with the Second Circuit last winter.
“From 2008 to 2014, the Western District's overall case filings and criminal felony filings, per judgeship, consistently were the highest of any district with in the Second Circuit and among the highest of any judicial district nationwide,” they wrote.
But ”at the same time, two of the district's four active judges took senior status, fueling a growing case backlog,” the Schulte Roth lawyers continued.
“According to the Administrative Office of the U.S. Courts, a judicial emergency persisted in the Western District due to these vacancies from June 2009 to the end of 2013.… By 2014, the delay-plagued Western District had an incredibly large caseload—the sixth-highest backlog in the country—and its median disposition time for criminal felony cases had climbed to 15.7 months, more than double the national average and the 10th worst nationwide.”
In a footnote, the attorneys quoted a 2014 article from The Buffalo News that pointed out that “the federal court caseload in the Western District of New York is immense, with the judges collectively handling more criminal cases than their counterparts in the nation's capital and Cleveland.”
Still, Schulte Roth's 81-page brief laid out many more reasons for what it characterized as inexcusable delay. One maneuver or tactic by the government after another—from judge decisions to aggressive prosecutorial stances—contributed to a stripping of Tigano's rights, they contended.
As one example of poor magistrate planning, Stein and Gladstein wrote that “even if the district court had properly referred the suppression motions to a magistrate, splitting up the motions between two magistrates was incompatible with its affirmative obligation to bring Tigano's case to trial promptly.
“Proper case management should have led the court to refer both motions to Magistrate McCarthy,” they continued. “The two motions related to the same search involving the same agents.”
They also argued that, at one point, Tigano, who has had some mental health issues, was wrongly forced into an extended competency hearing by the court precisely because he had been asking—from almost the time of his arrest—for a speedy trial, which was his right.
In addition, the lawyers contended that unsuccessful plea negotiations dragged on for almost a year as government prosecutors failed to produce a written plea agreement. Then, later, when another round of plea negotiations took place, prosecutors wrongfully sought to use a previous marijuana conviction to force Tigano into a weaker bargaining position. According to the lawyers, then-U.S. Attorney Eric Holder's policy at the time made clear that prosecutors should not use a prior drug conviction such as Tigano's against him in the bargaining process.
On Thursday, Joseph Karaszewski, an assistant U.S. attorney and the Western District's chief of appeals, who helped handle the Second Circuit briefing and argument for prosecutors, said by phone that he had no comment on the Second Circuit panel's order dismissing the indictment against Tigano and releasing him.
“There is a terse order, and we will wait to see what the court says in the opinion,” he said. He also declined to say whether prosecutors would seek to appeal the order, again noting that they first wanted to receive and read the opinion.
Tigano was arrested and charged, along with his father, in 2008. He faced six counts, including manufacturing 1,000 or more marijuana plants, possession with intent to distribute, and being a felon in possession of a firearm, according to documents.
DEA agents found at least 1,400 marijuana plants growing inside his home, documents said. His father, Joseph Tigano Sr., took a plea deal in the years afterward and avoided jail time. But Tigano III, the son, was locked away during the pretrial process even as he pleaded for a speedy trial and a resolution of his case, said Stein in a phone interview on Wednesday evening.
Early on, prosecutors had said his case would not take long to try—just a week or less.
After Tigano was put before a jury in 2015, the trial ran for five days. He was convicted of manufacturing marijuana and intent to distribute. At his sentencing, U.S. District Judge Elizabeth Wolford—taking over the matter from former Chief Judge William Skretny, who was assigned to the case throughout most of its duration—said she believed his 20-year sentence was too long, but that her hands were tied by mandatory minimum sentencing rules that apply to a previous offender.
The Buffalo News has said that Tigano's case became one of those cited around the country by advocates who argue against such drug sentencing minimums in the federal system.
Gladstein on Thursday said that his pro bono work on the Tigano case was a high point in a lengthy career. He'd believed strongly in his client's case and rights, and took the fight “personally,” he said.
“It was an opportunity to give to Joe the type of legal defense that I think everyday defendants should be entitled to,” he said. “It was something we took humbly and seriously, and I am elated that were able to come through for him.”
He noted that based on the firm's research, “this [Tigano's incarceration] was the longest term of pretrial incarceration that we were able to identify in this history of the Second Circuit's speedy trial jurisprudence.”
Stein said more than 90 percent of the oral argument in October focused on the Sixth Amendment speedy trial issue. He also said that the Second Circuit has not reversed a conviction based on a defendant's Sixth Amendment speedy trial right being violated since 1979. He and Gladstein both noted associates Andrew Joyce, Stephanie Kelly and Abigail Coster's work on the case.
Gladstein, still feeling high from the win, described the scene inside Schulte's Manhattan offices when the order popped onto his computer screen Wednesday.
“The email hit the inbox at 12:34 p.m.,” he said. “I opened it. I was shaking. The first thing I saw in big bold letters was 'Reversed.' I just started yelling. At the same time, Gary is sprinting down the hallway. Everybody comes out. As we realized what just happened, there were tears. It was a really emotional moment for everybody. We had dedicated ourselves to this case and we really believed in what we were arguing.”
A criminal defendant who waited seven long years for his trial has been released from prison a decade early.
An overloaded calendar in the U.S. District Court for the Western District of
A full opinion from the Second Circuit panel is forthcoming. But oral arguments in the case, extensive briefing and the “with prejudice” dismissal of all charges against Tigano indicate that the panel found his Sixth Amendment constitutional right to a speedy trial was violated.
Whether the panel's opinion cites that as the precise reason for its ruling or not, the result of its order issued Wednesday is clear: Tigano, 53, walks from prison a free man more than a decade before his mandatory minimum sentence of 20 years was set to end. In the federal system, while defendants can win early release, most serve all or nearly all of their sentences.
According to court documents, Tigano was arrested by Drug Enforcement Administration agents at his home near Buffalo, in Chautauqua County, in July 2008.
His five-day trial didn't happen until May 2015.
In all, he spent more than seven years behind bars during the pretrial process, and another two years in prison after his conviction. On Wednesday night at about 11:30, he left Schuylkill federal correctional institution in Pennsylvania and walked into the arms of waiting family members, according to lawyers.
Tigano's pro bono attorneys at
“The record in this case can only properly be understood in the context of the caseload crisis that gripped the Western District of
“From 2008 to 2014, the Western District's overall case filings and criminal felony filings, per judgeship, consistently were the highest of any district with in the Second Circuit and among the highest of any judicial district nationwide,” they wrote.
But ”at the same time, two of the district's four active judges took senior status, fueling a growing case backlog,” the
“According to the Administrative Office of the U.S. Courts, a judicial emergency persisted in the Western District due to these vacancies from June 2009 to the end of 2013.… By 2014, the delay-plagued Western District had an incredibly large caseload—the sixth-highest backlog in the country—and its median disposition time for criminal felony cases had climbed to 15.7 months, more than double the national average and the 10th worst nationwide.”
In a footnote, the attorneys quoted a 2014 article from The Buffalo News that pointed out that “the federal court caseload in the Western District of
Still,
As one example of poor magistrate planning, Stein and Gladstein wrote that “even if the district court had properly referred the suppression motions to a magistrate, splitting up the motions between two magistrates was incompatible with its affirmative obligation to bring Tigano's case to trial promptly.
“Proper case management should have led the court to refer both motions to Magistrate McCarthy,” they continued. “The two motions related to the same search involving the same agents.”
They also argued that, at one point, Tigano, who has had some mental health issues, was wrongly forced into an extended competency hearing by the court precisely because he had been asking—from almost the time of his arrest—for a speedy trial, which was his right.
In addition, the lawyers contended that unsuccessful plea negotiations dragged on for almost a year as government prosecutors failed to produce a written plea agreement. Then, later, when another round of plea negotiations took place, prosecutors wrongfully sought to use a previous marijuana conviction to force Tigano into a weaker bargaining position. According to the lawyers, then-U.S. Attorney Eric Holder's policy at the time made clear that prosecutors should not use a prior drug conviction such as Tigano's against him in the bargaining process.
On Thursday, Joseph Karaszewski, an assistant U.S. attorney and the Western District's chief of appeals, who helped handle the Second Circuit briefing and argument for prosecutors, said by phone that he had no comment on the Second Circuit panel's order dismissing the indictment against Tigano and releasing him.
“There is a terse order, and we will wait to see what the court says in the opinion,” he said. He also declined to say whether prosecutors would seek to appeal the order, again noting that they first wanted to receive and read the opinion.
Tigano was arrested and charged, along with his father, in 2008. He faced six counts, including manufacturing 1,000 or more marijuana plants, possession with intent to distribute, and being a felon in possession of a firearm, according to documents.
DEA agents found at least 1,400 marijuana plants growing inside his home, documents said. His father, Joseph Tigano Sr., took a plea deal in the years afterward and avoided jail time. But Tigano III, the son, was locked away during the pretrial process even as he pleaded for a speedy trial and a resolution of his case, said Stein in a phone interview on Wednesday evening.
Early on, prosecutors had said his case would not take long to try—just a week or less.
After Tigano was put before a jury in 2015, the trial ran for five days. He was convicted of manufacturing marijuana and intent to distribute. At his sentencing, U.S. District Judge Elizabeth Wolford—taking over the matter from former Chief Judge William Skretny, who was assigned to the case throughout most of its duration—said she believed his 20-year sentence was too long, but that her hands were tied by mandatory minimum sentencing rules that apply to a previous offender.
The Buffalo News has said that Tigano's case became one of those cited around the country by advocates who argue against such drug sentencing minimums in the federal system.
Gladstein on Thursday said that his pro bono work on the Tigano case was a high point in a lengthy career. He'd believed strongly in his client's case and rights, and took the fight “personally,” he said.
“It was an opportunity to give to Joe the type of legal defense that I think everyday defendants should be entitled to,” he said. “It was something we took humbly and seriously, and I am elated that were able to come through for him.”
He noted that based on the firm's research, “this [Tigano's incarceration] was the longest term of pretrial incarceration that we were able to identify in this history of the Second Circuit's speedy trial jurisprudence.”
Stein said more than 90 percent of the oral argument in October focused on the Sixth Amendment speedy trial issue. He also said that the Second Circuit has not reversed a conviction based on a defendant's Sixth Amendment speedy trial right being violated since 1979. He and Gladstein both noted associates Andrew Joyce, Stephanie Kelly and Abigail Coster's work on the case.
Gladstein, still feeling high from the win, described the scene inside Schulte's Manhattan offices when the order popped onto his computer screen Wednesday.
“The email hit the inbox at 12:34 p.m.,” he said. “I opened it. I was shaking. The first thing I saw in big bold letters was 'Reversed.' I just started yelling. At the same time, Gary is sprinting down the hallway. Everybody comes out. As we realized what just happened, there were tears. It was a really emotional moment for everybody. We had dedicated ourselves to this case and we really believed in what we were arguing.”
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