Narrative Opinion Summary
In this case, a petitioner sought a writ of prohibition to halt a circuit court trial on felony charges, alleging a breach of the speedy trial rule under the Florida Rule of Criminal Procedure 3.191. The petitioner was arrested in April 1984 and later released, subsequently moving from Florida to Kentucky, where he properly notified the court of his address change. An information was filed in August 1984, setting an arraignment date in September, but the notice was mistakenly sent to his former Florida address, leading to a failure to appear and the issuance of an arrest warrant. The petitioner was rearrested in February 1986, after the expiration of the speedy trial period, prompting a motion for discharge. The trial court denied this motion, incorrectly suggesting noncompliance with address notification. The appellate court found the trial court's conclusions unsupported by evidence, as the petitioner had adhered to notification requirements, and the failure to appear was due to clerical error. Consequently, the appellate court granted the writ of prohibition, remanding the case with instructions to discharge the petitioner, emphasizing adherence to procedural rules and the defendant's right to a speedy trial.
Legal Issues Addressed
Address Notification Compliancesubscribe to see similar legal issues
Application: A defendant is deemed compliant with address notification requirements if they have used the appropriate form to inform the court of any address changes.
Reasoning: Keehn...notified the circuit court of his address change using the appropriate form...The court's conclusions were unsupported by evidence, as Keehn had complied with address notification requirements.
Notice Requirements for Arraignmentsubscribe to see similar legal issues
Application: The sending of arraignment notice to an incorrect address due to clerical error does not constitute a failure by the defendant to comply with notification obligations.
Reasoning: Keehn...notified the circuit court of his address change using the appropriate form...notice of the arraignment was sent only to the Tampa address and was returned undeliverable.
Speedy Trial Rule under Florida Rule of Criminal Procedure 3.191subscribe to see similar legal issues
Application: The pre-1985 amendment rules required the trial to occur within a specific period, and the failure to do so entitled the defendant to discharge.
Reasoning: Keehn was arrested in February 1986, after the speedy trial period had expired, and moved for discharge.
Writ of Prohibition as a Remedysubscribe to see similar legal issues
Application: A writ of prohibition is appropriate to prevent a court from proceeding on charges where procedural rules have been violated.
Reasoning: Ronald Keehn petitioned for a writ of prohibition to prevent the circuit court from proceeding with trial on felony charges, claiming a violation of the speedy trial rule.