Commonwealth v. Checo

19 Pa. D. & C.5th 260
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedOctober 20, 2010
Docketno. 883 Criminal 2009
StatusPublished

This text of 19 Pa. D. & C.5th 260 (Commonwealth v. Checo) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Monroe County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Checo, 19 Pa. D. & C.5th 260 (Pa. Super. Ct. 2010).

Opinion

SIBUM, J.,

Defendant has filed a pretrial motion requesting that he be discharged from [261]*261prosecution for failure of the Commonwealth to comply with rule 600 of the Pennsylvania Rules of Criminal Procedure. In his motion, defendant also renews a prior pretrial motion seeking to exclude from evidence at trial the preliminary hearing transcript of a deceased witness. For the reasons that follow, we will deny defendant’s motion.

BACKGROUND

Defendant was arrested on April 16, 2009 on drug charges. A criminal complaint was filed that same day charging defendant with possession with intent to deliver a controlled substance, heroin, and a number of related offenses.

Defendant’s preliminary hearing was held on May 20, 2009 at which time all charges were bound over for court. Defendant was arraigned on July 6, 2009 and placed on the September 2009 criminal trial term. On July 14, 2009, defendant’s counsel filed a motion to withdraw. Hearing on the motion was held on July 28, 2009 at which time the court granted counsel’s motion. Due to a conflict in the public defender’s office, which rendered it unable to represent the defendant, the public defender filed a motion to appoint conflict counsel on August 18, 2009. The next day, August 19, 2009, attorney Jason Leon was appointed as counsel for the defendant.

The defendant, through his attorney, filed a motion to compel discovery on October 21, 2009, which was immediately prior to the first call of the November criminal trial list. Hearing on the defendant’s motion was held on November 18, 2009, which was after the date for jury selection for the November criminal trial term. At [262]*262the November 18, 2009 hearing on defendant’s motion, counsel advised the court that the discovery issues had been resolved between the parties and that the motion was now moot. The court issued an order at the November 18, 2009 hearing in which it indicated that the discovery motion was moot. The court’s November 18, 2009 order also extended the deadline for defendant to file an omnibus pretrial motion for thirty (30) days.

On December 18,2009, the last day in which defendant had to file an omnibus motion, defendant did in fact file such motion. Hearing on the motion occurred on January 12,2010, a date after the date reserved for jury selection for the January criminal trial term. A decision on defendant’s motion was not issued by the court until March 25,2010, a date after the date for jury selection for the March criminal trial term.

On April 19, 2010, defendant filed a motion to exclude the preliminary hearing transcript from evidence. The filing of defendant’s motion to exclude the transcript occurred directly prior to the call of the May criminal trial list. A hearing on defendant’s motion to exclude transcript was held on April 29, 2010, and a decision on the motion was not issued by the court until June 3, 2010, which was after the conclusion of the May criminal trial term.

The case was then scheduled for the July 2010 criminal trial term, a jury was empanelled, and testimony began on August 4, 2010. At the August 4, 2010 trial, counsel for the defendant uncovered discovery sitting on the assistant district attorney’s table which had not been turned over by the Commonwealth to the defendant. Due to the nature of the discovery, this court granted defendant’s motion for [263]*263mistrial due to concern that the newly discovered evidence may have presented a conflict of interest for defendant’s counsel, which issue needed further investigation. The defendant’s case was then placed on the next trial term, September 2010 criminal term of court.

On September 1, 2010, immediately prior to the commencement of the September 2010 criminal trial term, defendant filed the present motion. We are now prepared to dispose of defendant’s motion.

DISCUSSION

In his motion, defendant argues that he should be discharged from prosecution because his rights to a speedy trial under Rule 600 of the Pennsylvania Rules of Criminal Procedure have been violated. Rule 600, Prompt Trial, reads in relevant part, as follows:

(A)(2) Trial in a court case in which a written complaint is filed against the defendant, when the defendant is incarcerated on that case, shall commence no later than 180 days from the date on which the complaint is filed.
(3) Trial in a court case in which a written complaint is filed against the defendant, when the defendant is at liberty on bail, shall commence no later than 365 days from the date on which the complaint is filed.
(C) In determining the period for commencement of trial, there shall be excluded therefrom:
(1) the period of time between the filing of the written complaint and the defendant’s arrest, provided that the defendant could not be apprehended because his [264]*264or her whereabouts were unknown and could not be determined by due diligence;
(2) any period of time for which the defendant expressly waives rule 600;
(3) such period of delay at any stage of the proceedings as results from:
(a) the unavailability of the defendant or the defendant’s attorney;
(b) any continuance granted at the request of the defendant or the defendant’s attorney.
(E) No defendant shall be held in pretrial incarceration on a given case for a period exceeding 180 days excluding time described in paragraph (C) above. Any defendant held in excess of 180 days is entitled upon petition to immediate release on nominal bail. Pa.R.Crim.P. §600.

Pa.R.Crim.P. §600 “provides for dismissal of charges only in cases in which the defendant has not been brought to trial within the term of the adjusted run date, after subtracting all excludable and excusable time.” Commonwealth v. Murray, 879 A.2d 309, 314 (Pa. Super. 2006). The burden of ensuring that trial is commenced in a timely manner rests with the Commonwealth, not the defendant. Commonwealth v. McCutcheon, 488 A.2d 281, 284 (Pa. Super. 1985). The Commonwealth must demonstrate by a preponderance of evidence that it exercised due diligence in attempting to timely bring a case to trial. Commonwealth v. Johnson, 592 A.2d 706, [265]*265709 (Pa. Super. 1991). The standard of due diligence does not require the Commonwealth to exercise eveiy conceivable effort, but rather requires the Commonwealth to make reasonable efforts to bring a case to trial in a timely manner. Id. See also Commonwealth v. Wentzel, 641 A.2d 1207, 1209 (Pa. Super. 1994).

When a case has a possible rule 600 problem, prosecutors must do everything reasonable within their power to see that the case is tried on time. Commonwealth v. Aaron, 804 A.2d 39,44 (Pa. Super. 2002).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Paddy
800 A.2d 294 (Supreme Court of Pennsylvania, 2002)
Commonwealth v. McCutcheon
488 A.2d 281 (Supreme Court of Pennsylvania, 1985)
Commonwealth v. Wentzel
641 A.2d 1207 (Superior Court of Pennsylvania, 1994)
Commonwealth v. McGrogan
568 A.2d 924 (Supreme Court of Pennsylvania, 1990)
Commonwealth v. Aaron
804 A.2d 39 (Superior Court of Pennsylvania, 2002)
Commonwealth v. Johnson
758 A.2d 166 (Superior Court of Pennsylvania, 2000)
Commonwealth v. Johnson
592 A.2d 706 (Superior Court of Pennsylvania, 1991)
Commonwealth v. Hill
736 A.2d 578 (Supreme Court of Pennsylvania, 1999)
Commonwealth v. Bazemore
614 A.2d 684 (Supreme Court of Pennsylvania, 1992)
Commonwealth v. Murray
879 A.2d 309 (Superior Court of Pennsylvania, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
19 Pa. D. & C.5th 260, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-checo-pactcomplmonroe-2010.