State v. A.B.
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The Supreme Court affirmed the decision of the trial court granting Defendant's motion to dismiss the information against him, holding that the trial court did not err in concluding that the statute of limitations was not tolled by Conn. Gen. Stat. 54-193(c).
Defendant was charged with possession of child pornography in the first degree. Pursuant to a warrant, Defendant was arrested nearly five years after the warrant was issued and more than three years after the applicable statute of limitations had expired. The trial court granted Defendant's motion to dismiss, concluding (1) the tolling provision of section 54-193(c) was inapplicable once the warrant was issued within the limitation period, and (2) the almost five-year delay in executing the warrant was unreasonable under State v. Crawford, 521 A.2d 1034 (Conn. 1987). The Supreme Court affirmed, holding that although section 54-193 (c) tolls the limitation period within which a prosecution may be commenced, Crawford and its progeny establish that, once an arrest warrant has been issued, the State must serve the warrant without undue delay.
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