State v. Knox
1985 Mo. App. LEXIS 4158, 697 S.W.2d 261 (1985)
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Rule of Law:
A trial court possesses the inherent authority to dismiss a criminal case for unreasonable delay in bringing a defendant to trial, even under a speedy trial statute that does not specify a dismissal sanction or a precise time limit, when the state fails to provide a reasonable explanation for the delay after the defendant requests a speedy trial.
Facts:
- Jay Knox was charged with the offenses of burglary and stealing alleged to have been committed on November 6, 1983.
- Knox was arraigned on January 19, 1984.
- Knox obtained two continuances of his trial, first to April 16, 1984, and then to May 14, 1984.
- Defense counsel was engaged in another trial on May 14, 1984, leading to a trial reset for July 9, 1984.
- The state obtained a continuance, and the case was subsequently reset for August 6, 1984.
- On July 10, 1984, Knox filed a motion requesting a speedy trial.
- From August 6, 1984, until October 22, 1984, there was no record of any trial setting, request, or order of continuance.
Procedural Posture:
- Jay Knox was charged with burglary and stealing.
- Knox was arraigned in state trial court (court of first instance).
- Knox filed a motion for dismissal in October 1984, asserting he had not been tried on the charges.
- The trial court granted Knox's motion for dismissal.
- The state appealed the dismissal to the Missouri Court of Appeals.
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Issue:
Does a trial court have the authority to dismiss a criminal case for unreasonable delay, even under a speedy trial statute that requires only a trial setting "as soon as reasonably possible" and does not specify dismissal as a sanction, when the state fails to justify the delay after the defendant requests a speedy trial?
Opinions:
Majority - Clark, Judge
Yes, a trial court does have the authority to dismiss a criminal case for unreasonable delay, even under a speedy trial statute that requires only a trial setting "as soon as reasonably possible" and does not specify dismissal as a sanction, when the state fails to justify the delay after the defendant requests a speedy trial. The court assumed, for the purposes of this appeal, that the new speedy trial statute (§ 545.780, RSMo.Supp.1984), which mandates setting cases for trial "as soon as reasonably possible" after a request, applied to Knox’s case. The court held that trial courts possess inherent authority to dismiss cases for failure to prosecute with due diligence, citing Shirrell v. Missouri Edison Company (a civil case), and found no valid reason why this inherent authority should not extend to criminal cases. To deny this power would render the speedy trial request and the statute "futile and meaningless." The court articulated that when a defendant makes a prima facie showing of noticeable delay after filing a speedy trial motion, the state bears the burden to adduce evidence explaining the cause for the delay. Review of a trial court’s finding of unreasonable delay follows the Murphy v. Carron standard, meaning it will be affirmed unless there is no substantial evidence to support it, it is against the weight of the evidence, or it erroneously declares or applies the law. In Knox’s case, the record showed no trial setting or explanation for the delay from August to October after Knox requested a speedy trial, and the state offered no argument that Knox was responsible for the delay or that it was due to reasons beyond the state’s control. Therefore, the trial court’s finding of unreasonable delay was supported by substantial evidence.
Analysis:
This case is significant for clarifying that trial courts maintain an inherent judicial authority to dismiss criminal cases for unreasonable prosecutorial delay, even when the applicable speedy trial statute (here, the 1984 Missouri statute) lacks specific time limits or explicit dismissal as a sanction. It reinforces the constitutional burden on the state to provide a speedy trial and establishes a clear procedural framework: once a defendant makes a prima facie showing of delay, the onus shifts to the prosecution to justify the delay. This ruling empowers trial judges to enforce the spirit of speedy trial rights, preventing prosecutorial inaction from rendering such statutes ineffectual and influencing how prosecutors manage their dockets in response to demands for expedited trials.
