State v. Taylor
729 S.W.2d 483, 1987 Mo. App. LEXIS 3736 (1987)
Rule of Law:
The Interstate Agreement on Detainers (IAD) mandates the dismissal with prejudice of charges against a prisoner if they are not brought to trial within 180 days of requesting final disposition, unless the delay is specifically attributable to the prisoner or supported by legally recognized good cause, and a state's subjective beliefs about a defendant's future actions or misinterpretations of a court's temporary orders do not constitute such good cause.
Facts:
- Appellant Taylor was arrested on April 21, 1980, in Indianapolis, Indiana, on charges stemming from California.
- On May 7, 1980, Ray Gibson, a victim of the Missouri crimes, identified Taylor in a lineup held in the Marion County, Indiana jail.
- On May 9, 1980, complaints were filed in Platte County, Missouri, charging Taylor with rape, robbery, and sodomy, allegedly occurring on March 23, 1980.
- On October 30, 1980, Taylor was extradited from Indiana to California.
- The Platte County prosecutor lodged a detainer against Taylor in California.
- Taylor began serving a California sentence on January 12, 1982.
- While imprisoned in California, Taylor initiated a request for final disposition of the Missouri charges under the Interstate Agreement on Detainers (§ 217.490), which Missouri authorities timely received.
- From January 5, 1982, until January 12, 1983, Taylor was held by order of a California court as a witness in an unrelated crime.
Procedural Posture:
- On May 9, 1980, criminal complaints were filed in Platte County, Missouri, charging Taylor.
- On October 30, 1980, the Platte County prosecutor lodged a detainer against Taylor in California.
- On August 30, 1983, Taylor filed a motion to dismiss the charges pursuant to § 217.490, which the trial court overruled.
- Taylor subsequently filed petitions for writs of prohibition in the Missouri Court of Appeals, resulting in State ex rel. Taylor v. McFarland, arguing he was not brought to trial within 180 days.
- The Missouri Court of Appeals quashed the preliminary rules in Taylor v. McFarland, finding that certain periods (e.g., when Taylor was held as a witness, and for pretrial motions/continuances) tolled the IAD's time limits, thereby allowing the trial to proceed.
- The Missouri Supreme Court denied transfer of Taylor v. McFarland on October 9, 1984, making the appellate court's decision final.
- On November 10, 1984, Taylor filed a motion for a speedy trial under § 545.780 RSMo.
- On May 16, 1985, Taylor again moved to dismiss the case based on a violation of the Interstate Agreement on Detainers, which the trial court overruled.
- Trial commenced on July 15, 1985, and a jury found Taylor guilty of rape, robbery, and sodomy, imposing consecutive sentences.
- Taylor appealed his convictions and sentences to the Missouri Court of Appeals.
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Issue:
Does the Interstate Agreement on Detainers (IAD) mandate dismissal of charges against a prisoner when the state fails to bring him to trial within 180 days of his request for final disposition, and the state's delay is based on its counsel's representation that the prisoner would seek federal relief or a mistaken belief about the ongoing effect of a prior 'stop order'?
Opinions:
Majority - Pritchard, Presiding Judge
Yes, the Interstate Agreement on Detainers (IAD) mandates dismissal of charges where the state fails to bring a prisoner to trial within the statutory period, and the state's claimed justifications for delay are found to be insufficient to toll that period. The court noted that 276 days elapsed between October 9, 1984 (when the prior writ of prohibition case, Taylor v. McFarland, became final and the IAD clock restarted), and the trial commencement on July 15, 1985, significantly exceeding the 180-day limit. The state offered two justifications for this delay: (1) appellant's counsel's representation that he would seek federal court relief, and (2) a good faith belief that the Missouri Court of Appeals' prior 'stop order' was still in effect. The court found neither justification reasonable or legally sufficient to toll the IAD's time limits. Taylor's motion for a speedy trial on November 10, 1984, plainly contradicted any prior representation about seeking federal relief, dispelling any reasonable belief for delay. Regarding the 'stop order,' the court clarified that it was a temporary procedural instrument that merged into the preliminary writ and was 'wiped out' upon the quashal of the writ and final judgment in Taylor v. McFarland; any doubt regarding its efficacy should have prompted a much earlier inquiry by the state. The court emphasized the mandatory nature of the IAD's dismissal provision under Article III, Paragraph 1, and Article IV, Paragraph 3, stating that failure to try a defendant within the specified periods, without good cause, mandates dismissal of charges with prejudice, without requiring the accused to show prejudice, citing precedents like State ex rel. Saxton v. Moore. Despite the heinous nature of the crimes, the court found no alternative but to order the dismissal of the charges with prejudice due to the IAD violation.
Analysis:
This case strongly affirms the mandatory and non-discretionary nature of the Interstate Agreement on Detainers' speedy trial provisions. It establishes a strict standard, clarifying that a state's subjective beliefs or misinterpretations of procedural orders do not constitute legally sufficient 'good cause' to justify delays beyond the IAD's deadlines. The ruling places a significant burden on prosecutors to diligently monitor IAD timelines and promptly seek trial settings once excludable periods cease, rather than relying on assumptions about defense actions. This case serves as a crucial reminder that procedural compliance with the IAD is paramount, ensuring that prisoner's rights to timely disposition of charges are upheld, even if it results in the dismissal of serious charges.
