State v. Peltier

Summary

The Washington Supreme Court held that a criminal statute of limitations does not affect a court’s subject matter jurisdiction, but instead limits the court’s statutory authority to enter judgment. A defendant may expressly waive the statute of limitations in a pretrial agreement when the limitations period for the underlying charges has not yet expired. The court reversed the lower courts and permitted the State to refile the original charges.

Holdings

1. A criminal statute of limitations does not affect a court's subject matter jurisdiction; instead, its expiration deprives the court of statutory authority to enter judgment or sentence on the charge.
2. A defendant may expressly waive a criminal statute of limitations when the limitations period for the underlying charge has not yet expired and the court therefore still has authority to sentence on the charge.
3. Peltier's express waiver precluded him from objecting to the refiling of the original charges on statute-of-limitations grounds, and the State could refile those charges.

Questions Presented

1. Whether a criminal statute of limitations deprives a court of subject matter jurisdiction or instead limits the court's statutory authority to enter judgment and sentence.
2. Whether a criminal defendant may expressly waive a criminal statute of limitations in a pretrial or stipulated trial agreement when the limitations period for the underlying charges has not yet expired.
3. Whether Peltier's agreement validly waived his objection to the untimely refiling of the original charges.

Disposition

reversed