Commonwealth v. Meadius

ARGUED: March 2, 2004 OPINION We allowed appeal in this matter to determine whether a criminal defendant's rule-based entitlement to a prompt trial was infringed when the Commonwealth filed a criminal complaint, withdrew that complaint, filed a second complaint listing identical charges, and then failed to bring the defendant to trial within one year of the first (but not the second) filing. On January 16, 2001, the Commonwealth filed a criminal complaint charging Appellant, David Meadius, with, inter alia, forgery and insurance fraud. The charges stemmed from allegations that Appellant had obtained an insurance policy using the identity of his deceased father, and then filed a false auto-theft claim with the insurance company. A preliminary hearing was scheduled for February 8, 2001, but that hearing was continued at the Commonwealth's request because the prosecuting attorney was scheduled to attend a continuing legal education (CLE) class that day. The hearing was rescheduled for March 8, 2001, but it had to be rescheduled a second time because a Commonwealth witness failed to appear. Over Appellant's objection, the hearing was postponed until March 22, 2001. On that date, however, the prosecution was again unprepared to proceed due to the absence of two essential Commonwealth witnesses, including the insurance company's special investigator, who failed to attend because his wife had recently given birth. Unwilling to grant another continuance, the district justice stated that he would dismiss the case if the prosecution did not withdraw the charges. Consequently, the Commonwealth withdrew the complaint.