Commonwealth v. Thrapp

36 Pa. D. & C.4th 162, 1997 Pa. Dist. & Cnty. Dec. LEXIS 79
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedFebruary 12, 1997
Docketno. 415 Criminal 1996
StatusPublished

This text of 36 Pa. D. & C.4th 162 (Commonwealth v. Thrapp) 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. Thrapp, 36 Pa. D. & C.4th 162, 1997 Pa. Dist. & Cnty. Dec. LEXIS 79 (Pa. Super. Ct. 1997).

Opinion

WALLACH MILLER, J.,

The defendant, David M. Thrapp, has been charged with forgery, theft by unlawful taking or disposition, receiving stolen property, and criminal conspiracy along with another defendant, an office manager for a local attorney, alleged to have taken large sums of money from law office accounts. However, the matter we now must consider does not go to the substance of these charges, but to the procedural actions of the prosecution. The defendant has filed a motion to dismiss the case with prejudice for an alleged violation of Pennsylvania Rule of Criminal Procedure 1100, also known as the speedy trial rule.

The acts allegedly committed by the defendant were performed on and between August 1, 1991 and December 16, 1992. On December 13, 1995, the Commonwealth filed a criminal complaint against the defendant. This complaint was signed by then County Detective John Hudson. The defendant was arrested and then released on bond, pending a preliminary hearing scheduled for January 8,1996, before District Justice Anthony Mangan.

On January 5,1996, the first assistant district attorney of Monroe County sent a letter to District Justice Mangan telling him that the Commonwealth was withdrawing the charges against Mr. Thrapp. No reason was given for this withdrawal. No hearing was held.

On April 3, 1996, a second criminal complaint was filed against defendant by Stroudsburg Police Sergeant John Baujan. The charges in this complaint are identical to the charges in the first complaint. The preliminary hearing on the second complaint was held May 21, 1996, and all charges were bound over. On December [165]*16524, 1996, defendant filed a motion to dismiss under Rule 1100. A hearing on defendant’s motion was held on January 3, 1997. At that hearing, the Commonwealth advised the court that the first complaint was withdrawn because “Detective Hudson had left the district attorney’s office and there was no one to prosecute the matter.”

The applicable provisions of the current Pennsylvania Rule of Criminal Procedure 1100 are:

“RULE 1100. PROMPT TRIAL . . .
“(a)(3) Trial in a court case in which a written complaint is filed against the defendant, where the defendant is at liberty on bail, shall commence no later than 365 days from the date on which the complaint is filed. . . ."

The defendant contends that the 365-day period has expired, and has moved for dismissal of the charges. The prosecution contends that it has not. The issue to be decided is whether the 365-day period begins to run from the filing of the first complaint or the filing of the second complaint. If the timing begins with the first complaint, then the 365-day period would have run on December 13, 1996. Should the second complaint be the proper starting point for the Rule 1100 period, then the Commonwealth has until April 3, 1997 to begin trial of the defendant.

The Commonwealth seemingly as an afterthought also made an alternative “tolling” argument that, should the first complaint be found to be the proper starting point of the Rule 1100 period, the Commonwealth would still have until sometime in March of 1997 to commence trial. The Commonwealth’s alternative argument would cause the 365-day period to be “tolled” from January 5, 1996, the withdrawal of the first complaint by the prosecution, until the filing of the second complaint on April 3, 1996. In deciding whether the first or second complaint is the proper starting point of the 365-day [166]*166period and, if necessary, whether the Commonwealth’s tolling argument has merit, we look to the extensive and sometimes conflicting case law from our appellate courts.

Prior to 1972, there was no Rule 1100, and Pennsylvania used a “two-term” rule to provide for the discharge from imprisonment of any accused who had not been tried during the second court term after his commitment. Commonwealth v. Hamilton, 449 Pa. 297, 297 A.2d 127 (1972). In Hamilton, the Supreme Court criticized the two-term rule, and suggested a statutory solution to set a specific time period in which a case should be brought to trial. The court also made mention of referring the matter to the Criminal Procedure Rules Committee for study and recommendation. Id. at 308-309, 297 A.2d at 133. As a direct result of Hamilton, Pa.R.Crim.P. 1100 was adopted by the legislature in 1973.

Three years after Hamilton, the Supreme Court made its first relevant ruling on the new Rule 1100 in Commonwealth v. Whitaker, 467 Pa. 436, 359 A.2d 174 (1976). Whitaker pointed out that the interim Rule 1100 time period would be 270 days, then becoming a regular period of 180 days. The Rule 1100 period was later modified upwards to 365 days for an accused that is not incarcerated. The Supreme Court also denied a tolling of Rule 1100 on a nolle prosequi entered by the prosecution. Id. at 439, 359 A.2d at 175. An important distinction from the current case is that only one criminal complaint was involved in Whitaker. However, the Whitaker court pointed out that to rule otherwise would mean that “[tjhrough the simple expedient of a nolle prosequi, the prosecution could indefinitely delay an accused’s trial, thereby frustrating the state[d] objective of Rule 1100, while at the same time, escaping the consequences of its violation.” Id. at 442, 359 A.2d at 176. Whitaker defined a nolle prosequi as “the vol[167]*167untary withdrawal by the prosecuting attorney of present proceedings on a particular bill of indictment.” Id. at 442, 359 A.2d at 177, citing Commonwealth v. McLaughlin, 293 Pa. 218, 142 A. 213 (1928). In recent years, a criminal information has replaced the bill of indictment used in Whitaker, and the above definition should, therefore, apply to criminal informations as well.

Another important distinction made by Whitaker was its emphasis of former Rule 1100(c), now part of the substance of current Rule 1100(g), as the only legitimate means of extending the Rule 1100 time period.1 To allow a nolle prosequi to toll the Rule 1100 period would permit an extension without complying with the standard for obtaining an extension. Id. at 443, 359 A.2d at 177. Whitaker was the first case to deal with the tolling issue, argued alternatively here, and one month after Whitaker was handed down by the Supreme Court, the Superior Court ruled in a case involving two complaints.

Commonwealth v. Mumich, 239 Pa. Super. 209, 361 A.2d 359 (1976), was the first case in which a violation of Rule 1100 was alleged where the time period had expired if calculated from the filing of the first complaint, but not from a second complaint. In determining the starting point of the Rule 1100 period, the court held that “under these circumstances, especially where no objection was voiced, we are satisfied that the magistrate acted within his discretion in dismissing the complaint and discharging appellant. . . . We read Rule 1100 on prompt trial as applying to complaints properly filed and not to defective complaints that are dismissed.” Id. at 213, 361 A.2d at 361.

[168]*168The court allowed the Rule 1100 period to run from the second complaint when the first complaint was (a) defective and (b) dismissed.

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Bluebook (online)
36 Pa. D. & C.4th 162, 1997 Pa. Dist. & Cnty. Dec. LEXIS 79, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-thrapp-pactcomplmonroe-1997.