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Marks v. State

Supreme Court of Alaska
Apr 21, 1972
496 P.2d 66 (Alaska 1972)

Summary

holding that an appellate court must "independently review the proceedings below to insure that the error confessed is supported by the record on appeal and has legal foundation"

Summary of this case from Groom v. State

Opinion

No. 1414.

April 21, 1972.

Appeal from the Superior Court, Third Judicial District, Anchorage, James M. Fitzgerald, J.

Herbert D. Soll, Public Defender, Meredith A. Wagstaff and Lawrence J. Kulik, Asst. Public Defenders, Anchorage, for appellant.

John E. Havelock, Atty. Gen., Juneau, Seaborn J. Buckalew, Dist. Atty., Robert L. Eastaugh, Asst. Dist. Atty., Anchorage, for appellee.

Before BONEY, C.J., and RABINOWITZ, CONNOR, ERWIN and BOOCHEVER, JJ.


OPINION


Appellant has been sentenced to an eighteen-month term of imprisonment for the sale of a hallucinogenic drug in violation of AS 17.12.010. Prior to his trial appellant moved for dismissal of the criminal proceedings against him, arguing that dismissal was constitutionally mandated because eight months had elapsed between the occurrence of the alleged sale and the filing of the indictment. The denial of that pre-trial motion provides the sole claim of error on appeal.

The state, prior to filing its brief, filed in this court a confession of error, stating in part:

Following review of the record on appeal . . . and of the controlling authority, the State submits that the delay . . . taken in conjunction with the circumstances of the indictment and the prima facie showing of prejudice made by appellant at trial deprived Nelson Patrick Marks of his constitutionally protected rights.

Although a confession of error by the Attorney General is entitled to great weight, it does not relieve this court of the obligation to perform our judicial function. The public interest in criminal appeals does not permit their disposition by party stipulation. We must therefore independently review the proceedings below to insure that the error confessed is supported by the record on appeal and has legal foundation.

Although a few jurisdictions apparently reverse on a confession of error without further consideration, we feel that the better view is that such a confession is not binding on an appellate court. See, e.g., Sibron v. New York, 392 U.S. 40, 58, 88 S.Ct. 1889, 20 L.Ed.2d 917, 932 (1968); Young v. United States, 315 U.S. 257, 258, 62 S.Ct. 510, 86 L.Ed. 832, 834-835 (1942).

Appellant was charged with having sold on August 28, 1969, two tablets of lysergic acid diethylamide (LSD) to Kenneth Foster, an Anchorage city policeman then working as a narcotics undercover agent. On September 25, 1969, less than one month after the alleged sale, a secret indictment and the resultant arrest warrant were issued; however, both mistakenly named as defendant "Michael Lee Marks." The error was eventually discovered, and, on April 23, 1970, the defective indictment was dismissed. On April 30, 1970, eight months after the occurrence of the alleged offense, the grand jury returned a true bill against appellant using his correct name.

Appellant's contention that the dilatory accusation deprived him of his federally guaranteed right to a speedy trial is foreclosed by a recent decision of the United States Supreme Court. In United States v. Marion, 404 U.S. 307, 92 S.Ct. 455, 30 L.Ed.2d 468 (1971), the Court held that the sixth amendment right of an accused to a speedy trial attaches only after the institution of some public criminal charge against him.

We need not here decide whether the speedy trial guarantee of Alaska Const. art. I, § 11, is similarly limited. We note only that the gravamen of appellant's complaint more accurately may be taken as presenting a question akin to a due process issue, centering around appellant's inability to defend himself at trial.

There is legal basis for appellant's alternative claim that the passage of eight months between the alleged offense and the indictment impaired his ability to defend himself and constituted a denial of due process. Although "the applicable statute of limitations . . . is . . . the primary guarantee against . . . overly stale criminal charges," it "does not fully define [a defendant's] rights with respect to the events occurring prior to indictment." Both the Alaska and federal constitutional guarantees of due process of law serve to protect a defendant against the hazards of pre-accusation delay.

U.S.Const. amend. XIV; Alaska Const. art. I, § 7.

United States v. Ewell, 383 U.S. 116, 122, 86 S.Ct. 773, 777, 15 L.Ed.2d 627, 632 (1966). See also Toussie v. United States, 397 U.S. 112, 114-115, 90 S.Ct. 858, 25 L.Ed.2d 156, 161 (1970). Such statutes represent legislative assessments of when a defendant's right to a fair trial should be presumed prejudiced because of dilatory accusation. They also provide a degree of predictability which cannot be duplicated in judicial decision. The general five-year statute of limitations in AS 12.10.010 is applicable to the charge at bar.

United States v. Marion, 404 U.S. 307, 324, 92 S.Ct. 455, 465, 30 L.Ed.2d 468, 480-481 (1971).

Two factors have been considered relevant in deciding whether substantial delay in accusation constitutes a denial of federal due process: the reasonableness of the delay and the probable prejudice accruing from the delay. In order to assess a claim of due process deprivation, the governmental interest in postponing accusation must be weighed against the defendant's interest in early notice of the charges against him. In sum, both the absence of a valid reason for pre-accusation delay and the fact of prejudice must be established in order to support a due process claim.

Powell v. United States, 122 U.S.App. D.C. 229, 352 F.2d 705, 708 (1965); Ross v. United States, 121 U.S.App.D.C. 233, 349 F.2d 210, 211 (1965). See also United States v. Lee, 413 F.2d 910, 912-913 (7th Cir. 1969) cert. denied, 396 U.S. 1022, 90 S.Ct. 595, 24 L.Ed.2d 515 (1970); United States v. Feinberg, 383 F.2d 60, 65 (2d Cir. 1967); Schlinsky v. United States, 379 F.2d 735, 737 (1st Cir.), cert. denied, 389 U.S. 920, 88 S.Ct. 236, 19 L.Ed.2d 265 (1967); United States v. Harbin, 377 F.2d 78, 79-80 (4th Cir. 1967); Foley v. United States, 290 F.2d 562, 566 (8th Cir. 1961).

The state has not attempted to justify on appeal the passage of eight months between the alleged sale and the indictment. Moreover, in its confession of error the state conceded that appellant at trial made a "prima facie showing of prejudice." That concession, made by a party with intimate knowledge of the case is entitled to great weight.

The state has neither attempted to explain the cause of the mistaken denomination on the September 25th indictment nor sought to justify the seven-month delay in its correction. Moreover, we can perceive no legitimate governmental interest which might have justified dilatory accusation. The state concedes that the case was neither complex, requiring prolonged pre-charge investigation, nor hinged on the testimony of an undercover agent whose identity the state did not want to reveal. Officer Foster had "blown" his cover by testifying before the grand jury in several cases during September of 1969.

After denying the sale, appellant testified that he and his possible witnesses had no recollection of the events of the day on which it was alleged to have occurred. Further, appellant was unable to contact other possible witnesses who had moved from the area.

The judgment of conviction is reversed, and the case is remanded to the superior court with direction to dismiss the indictment, with prejudice.


Summaries of

Marks v. State

Supreme Court of Alaska
Apr 21, 1972
496 P.2d 66 (Alaska 1972)

holding that an appellate court must "independently review the proceedings below to insure that the error confessed is supported by the record on appeal and has legal foundation"

Summary of this case from Groom v. State

holding that when the government concedes error in a criminal appeal, the appellate court has an obligation to "independently review the [trial court] proceedings . . . to insure that the [concession of] error . . . is supported by the record on appeal and has legal foundation"

Summary of this case from Schumacher v. State

holding that an appellate court must independently assess whether a concession of error "is supported by the record on appeal and has legal foundation"

Summary of this case from Takak v. State

holding that an appellate court must independently evaluate any concession of error by the State in a criminal case

Summary of this case from Sherwood v. State

holding that an appellate court must independently assess whether a concession of error "is supported by the record on appeal and has legal foundation"

Summary of this case from Nelson v. State

holding that an appellate court must independently assess whether a concession of error "is supported by the record on appeal and has legal foundation"

Summary of this case from Williams v. State

holding that an appellate court must independently review the proceedings below to ensure that the State's concession is supported by the record on appeal and has legal foundation

Summary of this case from Belluomini v. State

holding that an appellate court must independently review the proceedings below to ensure that the error confessed is supported by the record on appeal and has legal foundation

Summary of this case from Belluomini v. State

holding that a reviewing court may not accept a State's concession without first independently assessing its validity

Summary of this case from Binder v. State

holding that when the State concedes error in a criminal case, the appellate court must independently assess whether the State's concession is well-founded

Summary of this case from McGowen v. State

holding that when the government concedes error in a criminal appeal, the appellate court has an obligation to "independently review the proceedings . . . to insure that [the concession of] error . . . is supported by the record on appeal and has legal foundation"

Summary of this case from Bolton v. State

holding that when the government concedes error in a criminal appeal, the appellate court has an obligation to "independently review the [lower court] proceedings . . . to insure that the [confession of] error . . . is supported by the record on appeal and has legal foundation"

Summary of this case from Boles v. State

holding that in criminal cases, an appellate court must independently evaluate the government's concession of error

Summary of this case from Marshall v. State

holding that in criminal cases an appellate court must independently evaluate the government's concession of error

Summary of this case from Brown v. State

holding that, in criminal cases, an appellate court must independently evaluate the government's concession of error

Summary of this case from Malloy v. State

holding that an appellate court must independently assess the State's concession of error in a criminal case

Summary of this case from DeRushe v. State

holding that an appellate court must independently assess the State's concession of error in a criminal case

Summary of this case from Black v. State

holding that an appellate court must independently assess the State's concession of error in a criminal case

Summary of this case from Frank v. State

holding that an appellate court must independently assess the State's concession of error in a criminal case

Summary of this case from Goldsbury v. State

holding that an appellate court is obliged to in dependently evaluate any concession of error by the State in a criminal case

Summary of this case from Parker v. State

holding that a reviewing court must independently review a party's concession

Summary of this case from Bertilson v. State

reversing conviction with direction to trial court to dismiss indictment where the state Attorney General filed a confession of error and “conceded that [defendant-appellant] at trial made a ‘prima facie showing of prejudice.'”

Summary of this case from United States v. Banwari

requiring an appellate court to independently assess the State's concession of error in a criminal case

Summary of this case from Logan v. State

In Marks v. State, 496 P.2d 66 (Alaska 1972), a reversal was mandated where the state made no attempt to justify a pre-accusation delay of eight months in a narcotics sale case, and the defendant testified that his possible witnesses either had no recollection of the events on the day of the alleged offense or had moved from the area and could not be contacted.

Summary of this case from Dixon v. State

In Marks v. State, 496 P.2d 66, 68-69 (Alaska 1972), we reversed a conviction for a preindictment delay of eight months, which delay the state did not attempt to justify.

Summary of this case from Coffey v. State
Case details for

Marks v. State

Case Details

Full title:NELSON PATRICK MARKS, APPELLANT, v. STATE OF ALASKA, APPELLEE

Court:Supreme Court of Alaska

Date published: Apr 21, 1972

Citations

496 P.2d 66 (Alaska 1972)

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