California Supreme Court Agrees With Riverside County Case Dismissals
The California Supreme Court today unanimously rejected Riverside County District Attorney Rod Pacheco’s contention that criminal cases on the verge of dismissal because of time constraints warrant using all court resources — including family law courtrooms — for trial.
In a 7-0 decision written by Chief Justice Ronald M. George, the justices sided with a state appellate court in finding that the D.A.’s arguments in People v. Engram lacked merit.
The appeal arose from the September 2008 dismissal of Terrion Marcus Engram’s burglary case and 17 other cases due to lack of courtroom space.
Under the state’s speedy trial guarantee, defendants charged with felonies are entitled to go to trial within 60 days, and defendants facing misdemeanor charges are entitled to a jury hearing within 30 days.
Trials are often postponed at the request of both the prosecution and defense. However, according to the law, trailing a trial under a “time waiver” cannot continue without the consent of all parties.
Engram’s case and the other 17 defendants’ cases — all misdemeanors but two — had reached their constitutional deadlines in September 2008, and the defendants were not willing to agree to further trial continuances requested by the District Attorney’s Office.
Unable to secure a courtroom to which to assign the “last-day” cases, the calendar court judge handling them dismissed each one — despite prosecutors’ objections that with no criminal or civil courtrooms available, specialty courts reserved for family law proceedings, probate hearings and juvenile trials should be utilized.
At the time, Riverside County’s court system was burdened with a backlog of several hundred serious felony cases going back two or more years, and most civil court judges’ dockets were crowded with criminal matters.
“The district attorney asserts that dismissal (of Engram’s case) was improper because the trial court erred in determining that the lack of an available judge or courtroom did not constitute `good cause’ … to continue the trial to a later date,” George wrote.
“We conclude that this contention … lacks merit,” he said. “Past cases establish that when the lack of a judge or courtroom available to timely bring a criminal defendant to trial is fairly and reasonably attributable to the fault or neglect of the state, that circumstance does not constitute good cause to delay the defendant’s trial.”
The justices agreed with the trial court judge’s findings that family, probate and juvenile departments were not appropriate venues to dispose the 18 criminal cases, and that doing so would have “greatly increased the administrative burdens upon the court.”
In the last two years, the Riverside County Superior Court has expanded its use of “vertical assignment” courtrooms to expedite criminal hearings, many of which still end up before judges designated to hear civil matters.
