People v. Carpela

CourtSuperior Court of Guam
DecidedMarch 5, 2012
DocketCM1089-10
StatusUnknown

This text of People v. Carpela (People v. Carpela) is published on Counsel Stack Legal Research, covering Superior Court of Guam primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Carpela, (superctguam 2012).

Opinion

IN THE SUPERIOR COURT OF GUAM ~~~17 ::::~ - 5 Ai'l 10: 03 2 ) CRIMINAL CASE NO. CMI089-10 THE PEOPLE OF GUAM, 3 ) vs. ) 4 ) DECISION AND ORDER ) ON DEFENDANT'S MOTION TO 5 ) DISMISS ROGERLEE CRUZ CARPELA, 6 ) Defendant. ) 7 ) ) 8 9 This matter came before the HONORABLE VERNON P. PEREZ on November 22, 10 2011 on Defendant's Motion to Dismiss. Attorney Raymond B. Hagan represented Defendant, 11 who was present. Attorney James C. Collins appeared on behalf of the Government. Having 12 reviewed the pleadings, the arguments presented and the record, the Court now issues the 13 following Decision and Order. 14 BACKGROUND 15 Defendant is charged with Making a False Report as a Misdemeanor. Defendant 16 requests dismissal as he argues that the time from the filing of the criminal Complaint against 17 him to the time he was arraigned was in violation of the Prompt Arraignment Rule recently 18 handed down by the Supreme Court of Guam in People v. Rasauo, 2011 Guam 14 (hereinafter

19 "Rasauo If'). 20 DISCUSSION 21 Defendant argues that this case be dismissed for violation of the rule put forth in Rasauo 22 II. See also 8 GCA §60.1 O. The recent Supreme Court decision Rasauo II requires dismissal 23 where a defendant is not arraigned within 60 days of the date of filing of a formal criminal 24 complaint. Yet, as the Government argues, delay in arraignment may be excused where "good 25 cause" is shown. Id. at ~14. In Rasauo IL the Guam Supreme Court found that delay created 26 from the Government choosing to continue with a separate charge before proceeding on a 27 second crime was not good cause delay. Here, the Government alleges that their office was not 28 negligent in dealing with the Defendant and did the most that it could do to expedite

People v. Carpela, Decision and Order (Defendant's Motion to Dismiss) Criminal Case No. CM1089-10 - Page 1 of5- proceedings against Defendant. The Government believes that good cause delay exists where 2 the courts are at fault for setting first appearance hearings beyond 60 days from a formal 3 complaint. In furtherance of that contention, the Government puts forth that the Rasauo II 4 decision is focused on prosecutorial delay and does not apply the same strict standards for all 5 Government agencies affiliated with criminal proceedings that exist for the Speedy Trial Right. 6 8 GCA § 80.60. On the other hand, Defendant argues that even the Court and its officers are 7 subject to the Prompt Arraignment Right defmed in Rasauo 11 That is the crux of the issue 8 before the Court now. Does good cause delay exist where the Court system does not get a 9 defendant to arraignment until 60 days after the complaint was filed? 10 Defendant argues that Supreme Court, in Rasauo II, aligned prompt arraignment with the 11 Speedy Trial Right by applying the same 60 day standard for Defendant not incarcerated. 12 Defendant cites to another Guam Supreme Court decision which the Rasauo II Court also 13 quoted. In People v. Stephen, the Court stated that prompt arraignment is "a statutory

14 expression of the speedy trial right. 2009 Guam 8 ~32. Defendant argues that in dismissal 15 motions arising from a violation of the Speedy Trial Right, the courts may also be responsible 16 for the violation. In Speedy Trial Right violations, the remedy is the same as if the Government 17 created the delay, which is at minimum dismissal when no good cause is found. Defendant 18 concludes by arguing that if the Supreme Court intended to align prompt arraignment with the 19 Speedy Trial Right, that the standards applying to the Speedy Trial Right also apply. 20 The Government argues that the intent behind Rasauo II was not to ensure that the courts 21 promptly place all hearings for a Defendant's first appearance within 60 days. The Government 22 contends that the Guam Supreme Court meant only to deter prosecutorial delay or negligence in 23 prosecuting cases. In addition, the Government claims that it would be unreasonable to ask that 24 the calendar for many courts be subject to a 60 day window for arraignments of criminal 25 defendants. This Court interprets the Rasauo II decision such that the Superior Court is required 26 to adjust calendaring procedures in accordance with the Prompt Arraignment Rule put forth in 27 Rasauo II. 28 This Court finds no relevant controlling precedent in case law to base its decision, but

People v. Carpela, Decision and Order (Defendant's Motion to Dismiss) Criminal Case No. CM 1089-1 0 - Page 2 of 5 - finds it abundantly clear that the Supreme Court did imply that the courts are also responsible 2 for ensuring prompt arraignment. That intent is clear considering the Guam Supreme Court 3 declaring that "this principle is directly embodied in our statutory framework" and quoting 8 4 GCA §80.50(a) directly after that statement, which provides: 5 the welfare of the people of the territory of Guam requires that all proceedings in criminal cases shall be set for trial and heard and 6 determined at the earliest possible time, and it shall be the duty of 7 all courts and judicial officers and of all prosecuting attorneys to expedite such proceedings to the greatest degree that is consistent 8 with the ends of justice. (2006). 9 Therefore, the Supreme Court made it clear that it intended the Superior Court and its officers to 10 be subject to the Prompt Arraignment Rule put forth in Rasauo II Here, there were more than 11 60 days from complaint to arraignment and the Court created delay can require dismissal if there 12 is no good cause shown as determined above. The issue now becomes whether there was good 13 cause for delay that the Court and its officers created in arraigning the Defendant? 14 The Court dated the arraignment hearing to be January 19,2011 at 10:00a.m. when filing 15 the initial summons on December 15,2010. The Complaint was filed December 1,2010, which 16 means that the arraignment hearing was scheduled within the 60 day limit. Defendant did not 17 show and it is not known whether or not Defendant was adequately notified of that hearing. In a 18 perfect world, the Defendant would have been arraigned in less than 60 days after the Complaint 19 was file. Yet, Defendant did not appear and it is not clear whether or not Marshals put forth 20 enough effort to locate Defendant which would create a good cause excuse for violation of the 21 Prompt Arraignment Rule. It is abundantly clear, however, that if Defendant purposely delayed 22 service or intentionally failed to appear after being notified of a hearing date, good cause would 23 be found. It is also apparent that if the Defendant did nothing to delay service, or had no notice 24 of a hearing date, and the Marshalls put forth lackluster efforts to notify Defendant then good 25 cause would not be found. 26 As the Supreme Court said only good cause would prevent dismissal, it becomes the 27 Government's burden to show good cause once the 60 day window has expired. Yet, the 28 Government cites to a number of attempts in which the Marshalls tried serving Defendant with

People v. Carpela, Decision and Order (Defendant's Motion to Dismiss) Criminal Case No. CM1089-1O - Page 3 of 5 - the summons and eventually a bench warrant. The Magistrate Court's request for bench warrant 2 filed on February 24, 2011 included a checked off portion that stated "Reasonable and diligent 3 attempts were made by the Deputy Marshal to personally serve the defendant a copy of the 4 Summons, but without success". However, no attempts of service were logged in the Court file. 5 The Court must assume that a bench warrant was issued because locating the Defendant was 6 difficult as attempts at normal service failed to bring the Defendant to court.

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People v. Carpela, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-carpela-superctguam-2012.