United States Court of Appeals For the Seventh Circuit ____________________ No. 24-1765 UNITED STATES OF AMERICA, Plaintiff-Appellee, v. EFRAIN LEONIDES-SEGURIA, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:21-cr-00390-1 — John F. Kness, Judge ____________________

ARGUED DECEMBER 12, 2024 — DECIDED APRIL 18, 2025 ____________________

Before RIPPLE, SCUDDER, and MALDONADO, Circuit Judges. SCUDDER, Circuit Judge. Efrain Leonides-Seguria urges us to overturn his conviction for illegal reentry into the United States, contending the government violated the Speedy Trial Act by filing the criminal information more than 30 days after his apprehension on immigration charges. By its terms, the Act does not apply to civil custody, which includes Leonides- Seguria’s time in immigration detention. But several courts have carved out an exception when federal law enforcement 2 No. 24-1765 authorities collude with immigration officials to hold an indi- vidual on immigration charges as a mere ruse for later prose- cution—buying prosecutors time to build a criminal case without implicating the Act’s deadlines, while their target nevertheless remains in custody. Leonides-Seguria asks us to recognize this so-called “ruse exception.” This is not the case to resolve the question, though, as Leonides-Seguria’s appeal falls short of presenting circumstances that would give rise to its application. So we save the legal question for another day and affirm. I Efrain Leonides-Seguria is a citizen of Mexico without any claim to American citizenship or lawful residence here. On several occasions he has entered the United States illegally and, in turn, been removed by immigration authorities. On June 15, 2021, Immigration and Customs Enforcement again discovered Leonides-Seguria in the United States and detained him on administrative charges. Six days after taking Leonides-Seguria into custody, immigration officials referred him for criminal prosecution to the United States Attorney’s Office in Chicago. On June 23—within two days of receiving the referral—federal prosecutors filed a criminal complaint against Leonides-Seguria for illegal reentry into the United States. See 8 U.S.C. § 1326. A magistrate judge issued an arrest warrant that same day. Leonides-Seguria remained in immigration custody until June 28, when federal officials arrested him on the criminal complaint and brought him to federal court for his initial ap- pearance. Leonides-Seguria later waived prosecution by No. 24-1765 3 indictment and consented to the filing of a criminal infor- mation on July 27. The district court denied Leonides-Seguria’s motions to dismiss the federal charge on the grounds that the govern- ment violated the Speedy Trial Act and, separately, that § 1326 is unconstitutional. Leonides-Seguria then chose to plead guilty, reserving the right to appeal the denials of his motions to dismiss on both grounds. The district court sen- tenced him to 51 months’ imprisonment. Leonides-Seguria now appeals. II A The Sixth Amendment promises anyone accused of a crime “the right to a speedy and public trial.” This right limits the time during which criminal charges can hang over a de- fendant’s head. See United States v. Marion, 404 U.S. 307, 317– 18 (1971). For constitutional purposes, the “right to a speedy trial is triggered by an arrest, indictment, or some other offi- cial accusation.” United Sta