State v. Freeman (Concurrence)

CourtSupreme Court of Connecticut
DecidedAugust 30, 2022
DocketSC20554
StatusPublished

This text of State v. Freeman (Concurrence) (State v. Freeman (Concurrence)) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Freeman (Concurrence), (Colo. 2022).

Opinion

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The syllabus and procedural history accompanying the opinion as it appears in the Connecticut Law Journal and bound volumes of official reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced and distributed without the express written permission of the Commission on Official Legal Publica- tions, Judicial Branch, State of Connecticut. *********************************************** STATE v. FREEMAN—CONCURRENCE

ROBINSON, C. J., concurring in the judgment. I con- cur in this court’s judgment reversing the judgment of the Appellate Court, which affirmed the conviction of the defendant, Terry Freeman, of robbery in the first degree in violation of General Statutes § 53a-134 (a) (3), following the entry of a conditional plea of nolo contendere. See State v. Freeman, 201 Conn. App. 555, 568, 242 A.3d 1059 (2020). I agree with the court’s ulti- mate conclusion that the prosecution of the defendant was time barred by the five year statute of limitations set forth in General Statutes (Rev. to 2017) § 54-193 (b)1 on the ground that the state failed to establish that the warrant for the defendant’s arrest was executed without unreasonable delay. I write separately because I respect- fully disagree with those portions of the opinion announc- ing the judgment of the court2 holding that the ‘‘evi- dence’’ of the ‘‘reasonable efforts to execute the arrest warrant’’ after the running of the statute of limitations that are required by this court’s decisions in State v. Swebilius, 325 Conn. 793, 159 A.3d 1099 (2017), and State v. Crawford, 202 Conn. 443, 521 A.2d 1034 (1987), cannot be established by the factual representations of counsel. To the contrary, I conclude that the prosecu- tor’s personal involvement in and familiarity with arranging the process by which the defendant would be transported to court from the Carl Robinson Correc- tional Institution for service of the warrant rendered the prosecutor’s unchallenged factual representations an appropriate vehicle by which the state could estab- lish ‘‘evidence’’ of its efforts to serve the warrant after the lapse of the statute of limitations. Because I never- theless conclude that the facts established by those representations did not satisfy the state’s obligation to make reasonable efforts to serve the arrest warrant following the lapse of the statute of limitations, I concur in the judgment of the court. I note my agreement with the majority opinion’s reci- tation of the facts, procedural history, and governing legal principles as set forth by, inter alia, State v. Swebi- lius, supra, 325 Conn. 793, and State v. Crawford, supra, 202 Conn. 443. Specifically, I agree that, ‘‘[w]hen an arrest warrant has been issued, and the prosecutorial official has promptly delivered it to a proper officer for service, he has done all he can under our existing law to initiate prosecution and to set in motion the machin- ery that will provide notice to the accused of the charges against him. When the prosecutorial authority has done everything possible within the period of limitation to evidence and effectuate an intent to prosecute, the stat- ute of limitations is [satisfied].’’ (Footnote omitted.) State v. Crawford, supra, 450; see State v. A. B., 341 Conn. 47, 57 n.6, 266 A.3d 849 (2021) (explaining that ‘‘ ‘satisfie[d]’ is the appropriate term to describe the state’s meeting such obligation under’’ criminal statute of limitations). There must, ‘‘however, [be] some limit as to when an arrest warrant must be executed after its issuance . . . in order to prevent the disadvantages to an accused attending stale prosecutions, a primary purpose of statutes of limitation[s].’’ State v. Crawford, supra, 450. ‘‘[I]n order to [satisfy] the statute of limita- tions, an arrest warrant, when issued within the time limitations . . . must be executed without unreason- able delay.’’ Id., 450–51. In Crawford, this court declined to ‘‘adopt a per se approach as to what period of time to execute an arrest warrant is reasonable.’’ Id., 451. Instead, the court clari- fied that ‘‘[a] reasonable period of time is a question of fact that will depend on the circumstances of each case. If the facts indicate that an accused consciously eluded the authorities, or for other reasons was difficult to apprehend, these factors will be considered in determin- ing what time is reasonable. If, on the other hand, the accused did not relocate or take evasive action to avoid apprehension, failure to execute an arrest warrant for even a short period of time might be unreasonable and fail to [satisfy] the statute of limitations.’’ Id. In State v. Swebilius, supra, 325 Conn. 793, we recently held that even a very brief delay in the execu- tion of an arrest warrant following the lapse of the statute of limitations cannot ‘‘be reasonable as a matter of law . . . .’’ Id., 801; see id., 809–10. We then clarified the parties’ respective obligations with respect to the proof of a statute of limitations defense, observing that, ‘‘once the defendant has demonstrated his availability for arrest, he has done all that is required to carry his burden [of proving the statute of limitations defense]; the burden then shifts to the state to demonstrate that any period of delay in executing the warrant was not unreasonable.’’ Id., 804; see id., 803 (discussing Appel- late Court case law shifting burden ‘‘to the state to present evidence of its due diligence in executing the warrant’’). Requiring ‘‘the state to explain why, notwith- standing the defendant’s availability during the statu- tory period, the delay in his arrest was reasonable . . . allocates burdens efficiently by requiring each party to bring forth evidence uniquely within its knowledge.’’ Id., 807; see id., 808 (‘‘the state is in a far better position to determine what efforts were undertaken to ensure the defendant’s prompt arrest’’). We emphasized in Swebilius that ‘‘[t]his burden shift- ing scheme also encourages diligence by law enforce- ment officials in providing timely notice of charges to defendants. Although we decline[d] to specify the pre- cise actions that they must undertake to serve a warrant with due diligence, or the precise timeline within which they must act, such officials must present some credible and persuasive factual basis for inaction when they fail to observe the statute of limitations. This requirement is consistent with the principle that, when a judicial doctrine, for all practical purposes, extends the statute [of limitations] beyond its stated term, that doctrine should be applied in only limited circumstances . . . .

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Related

State v. Swebilius
159 A.3d 1099 (Supreme Court of Connecticut, 2017)
Cologne v. Westfarms Associates
496 A.2d 476 (Supreme Court of Connecticut, 1985)
State v. Crawford
521 A.2d 1034 (Supreme Court of Connecticut, 1987)
State v. Nguyen
756 A.2d 833 (Supreme Court of Connecticut, 2000)
State v. Chambers
994 A.2d 1248 (Supreme Court of Connecticut, 2010)

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State v. Freeman (Concurrence), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-freeman-concurrence-conn-2022.