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The federal district courts of the United States face a peculiar time crunch each time they confront a new criminal prosecution. Every year, federal judges must cope with tens of thousands of criminal cases which have become increasingly complex and time-consuming.' At the same time, the courts are procedurally constrained in terms of the amount of time they are permitted to devote to each new case. The Speedy Trial Act2 ("STA") mandates dismissal of any federal criminal case in which an indictment is not issued within thirty days of arrest or in which a trial does not begin within seventy days of indictment or arraignment. Designed by Congress to reduce recidivism and increase deterrence through the efficient administration of justice, the STA paradoxically threatens to thwart its own objectives whenever a complex and time-consuming prosecution comes before the courts. The drafters of the STA were cognizant of this danger and constructed the statute to accommodate it. Recognizing the practical need to reconcile the STA with the many unavoidable delays intrinsic to the criminal process, the drafters enumerated nine specific exclusions that toll the STA's time limits.3 Eight of the exclusions are specifically targeted to common sources of delay such as pretrial motions and joining of new codefendants. The ninth confers discretion upon judges to grant a continuance when necessary to serve the "ends of justice."4 These exclusions, espe-

Speedy Justice and Timeless Delays: The Validity of Open-Ended "Ends-of-Justice" Continuances under the Speedy Trial Act