This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant was convicted of forgery. Following this conviction, the State sought to enhance the Defendant's sentence under the Habitual Offender Act. The Defendant was arraigned on the supplemental information on August 4, 2000, and the six-month deadline for commencing trial under Rule 5-604 was February 4, 2001. The State filed a motion to extend the time for trial on January 5, 2001, but the district court did not act on the motion until February 22, 2001, after the six-month period had expired (paras 2-3).
Procedural History
- District Court, February 22, 2001: The district court denied the Defendant's motion to dismiss the supplemental information and granted the State's motion to extend the time for trial, despite the expiration of the six-month period (para 2).
Parties' Submissions
- Defendant-Appellant: Argued that the district court lacked authority to grant an extension of time to commence trial after the six-month period under Rule 5-604 had expired. The Defendant sought dismissal of the supplemental information (paras 1-2).
- Plaintiff-Appellee (State): Contended that Rule 5-604 should be read in conjunction with other procedural rules, such as Rule 5-601(F) and Rule 5-104(B), which allow courts a reasonable time to rule on motions. The State argued that the district court could grant the extension even after the six-month period had expired (paras 6-7).
Legal Issues
- Whether the district court may grant an extension of time to commence trial under Rule 5-604 after the six-month period has expired.
Disposition
- The Court of Appeals reversed the Defendant's sentence under the Habitual Offender Act (para 16).
Reasons
Per Wechsler J. (Bosson CJ and Robinson J. concurring):
The Court held that Rule 5-604 requires the district court to act on a timely-filed petition for an extension of time before the expiration of the six-month period for commencing trial. The language of Rule 5-604 is mandatory, stating that trial "shall be commenced" within six months unless an extension is granted within that period. The Court rejected the State's argument that Rule 5-604 should be read in conjunction with Rule 5-601(F) and Rule 5-104(B), emphasizing that Rule 5-604 is specific and takes precedence over the general provisions of other rules (paras 5, 13-14).
The Court also examined the history and structure of Rule 5-104(B) and concluded that the restriction on extending the time for commencement of trial applies to both pre- and post-expiration motions. The Court found that the district court lacked authority to grant the State's motion for an extension after the six-month period had expired, as this would undermine the purpose of Rule 5-604, which is to ensure the prompt disposition of criminal cases (paras 8-13).
The Court reversed the Defendant's sentence under the Habitual Offender Act because the trial did not commence within the required time frame, and the district court improperly granted the extension after the deadline (paras 15-16).