James v. Galetka

BENCH, Judge

(concurring in result):

Contrary to the position taken in the main opinion, the issue of whether criminal statutes of limitations are jurisdictional is not an issue of first impression in Utah. We have already stated that criminal statutes of limitations are jurisdictional in nature. See, e.g., State v. Price, 837 P.2d 578, 582-84 (Utah Ct.App.1992) (holding statutory limit on time for filing motion to withdraw guilty plea is jurisdictional); State v. Pierce, 782 P.2d 194, 196 (Utah Ct.App.1989) (holding criminal statute of limitations is jurisdictional bar to prosecution). The majority’s approach is, at a minimum, inconsistent with prior decisions of this court. See State v. Thurman, 846 P.2d 1256, 1269 (Utah 1993) (discussing doctrine of stare decisis).

This case is nonetheless affirmable under the rationale set forth in Waters v. United States, 328 F.2d 739 (10th Cir.1964), and United States v. Cooper, 956 F.2d 960 (10th Cir.1992). Both Waters and Cooper noted the jurisdictional nature of a criminal statute of limitations and concluded that “if the statute of limitations ‘is to have any meaning in the administration of criminal justice, [it] must be held ... to operate as a jurisdictional limitation upon the power to prosecute and punish.’ ” Cooper, 956 F.2d at 961-62 (quoting Waters, 328 F.2d at 743) (alteration in original).

The [Waters ] court did not equate the statute with the concept of subject matter jurisdiction, and we do not believe such a parallel exists. Moreover, while we agree with those courts which hold a defendant can waive the statute of limitations, we do not look upon such a waiver as a waiver of jurisdiction.
... [A] defendant can waive the bar to prosecution.... [I]t is most often done when the defendant perceives waiver will work to his or her advantage.
Thus, by waiving the statute, the defendant neither confers jurisdiction upon the court nor power upon the government to prosecute. In effect, the defendant’s waiver of the statute of limitations, in proper circumstances, is a binding agreement not to object to the filing of charges beyond the period of limitations. However, absent that agreement, ... the clear language of the statute of limitations prohibits the government from prosecuting beyond that time.

Id. at 962. Consequently, the fact that a criminal statute of limitations is a jurisdictional bar to prosecution does not mean that a criminal defendant cannot waive it as part of a plea bargain.

The result reached by the majority is also sustainable for another reason. Unlike the perjury charge that was discussed and rejected by trial counsel, the evidence-tampering charge relates back to the original information. See Utah R. Civ. P. 15(c) (stating amendment relates back to date of original pleading “[w]henever the claim or defense asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth or attempted to be set forth in the original pleading”); see also Utah R. Civ. P. 81(e) (“These rules of procedure shall also govern in any aspect of criminal proceedings where there is no other applicable statute or rule, provided, that any rule so applied does not conflict with any statutory or constitutional requirement.”). If a new claim relates back to the date of the original pleading, a party may include it even when the statute of limitations has otherwise run on that claim. See Ringwood v. Foreign Auto Works, Inc., 786 P.2d 1350, 1359 (Utah Ct.App.), cert. denied, 795 P.2d 1138 (Utah 1990).

The evidence-tampering charge in the present case arose out of the same occurrence that generated the original aggravated murder charge. The original information *576charged defendant with the aggravated murder of his infant son. Defendant concealed the infant’s body by discarding it in the Bear River Marina. Because the evidence-tampering charge was an integral part of the originally charged homicide, and was added without objection, it should relate back to the original information.

I therefore concur in the result reached by the main opinion, but not in its analysis of the statute of limitations.