United States v. Miklos Varga, Hans Christian Elley, Richard Theodore Jantos and Peter Armbruster. Miklos Varga

OPINION OF THE COURT

Miklos Varga appeals from his conviction of bank robbery in violation of 18 U.S.C. § 2113. His contentions are bottomed on alleged violations of the Sixth Amendment: first, the ten-month delay between indictment and trial violated his right to a speedy trial; second, he had ineffective assistance of counsel.

Four factors are considered when deciding whether a violation of the right to a speedy trial has occurred: “The length of the delay; the reason for the delay; the prejudice to the defendant; and waiver by the defendant.” United States v. Taddeo, 434 F.2d 228, 229 (2d…