Commonwealth v. Bradford
46 A.3d 693
| Pa. | 2012Background
- Defendant Bradford faced a September 21, 2008 kidnapping/rape case filed by Wilkinsburg Police; arrest and bail set at $100,000; he remained jailed after bail was not posted.
- Magisterial District Judge held preliminary hearing October 9, 2008 and bound charges over for court; proposed amendments added sexual assault-related charges.
- Judge failed to forward the preliminary hearing transcript to the Court Records within five days as required by Rule 547(B); CR number not generated, internal Rule 600 tracking not triggered.
- Bradford remained in jail until October 9, 2009, when he moved to dismiss under Rule 600, alleging trial delay beyond the 365-day mechanical run date.
- DA learned of the delay only after receipt of Bradford’s Rule 600 motion and then triggered a manual docketing process; trial was set for December 7, 2009.
- Trial court dismissed the charges on November 4, 2009; Superior Court affirmed; Commonwealth petitioned for review; Supreme Court reversed and reinstated charges, holding due diligence and judicial delay were beyond Commonwealth’s control.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Commonwealth exercised due diligence under Rule 600(G). | Bradford argues Commonwealth relied on judicial delay and failed to maintain its own tracking. | Bradford contends the delay was Commonwealth’s fault for not monitoring its cases; reliance on judiciary was unreasonable. | Yes; Commonwealth exercised due diligence despite judicial delay. |
| Whether reliance on District Judge’s compliance to trigger Rule 600 tracking was reasonable. | Bradford argues reliance on others to trigger tracking is inadequate. | Bradford relies on Monosky to say such delay is judicial, not prosecutorial. | Yes; reliance was reasonable and within due diligence. |
| Whether Browne’s record-keeping requirement applies to trigger due diligence here. | Bradford argues Browne requires a DA record-keeping system; failure means lack of due diligence. | Bradford contends Browne should be distinguished; DA had monitoring system here. | No; DA’s system and trigger mechanism satisfied due diligence. |
| Is it proper to reverse based on Monosky versus Browne distinctions given the DA’s awareness of charges? | Bradford emphasizes Monosky control by DA awareness; here DA was aware via preliminary hearing. | Bradford emphasizes reliance on judiciary; Monosky governs cases DA unaware of charges. | Yes; the case aligns with Monosky’s framing that due diligence can be met even with judicial delay. |
| Does judicial delay count as beyond Commonwealth’s control under Rule 600(G) given due diligence? | Bradford argues delay was beyond Commonwealth’s control due to judge’s failure to forward records. | Bradford argues this is within Commonwealth’s control; Browne requires proactive tracking. | Yes; delay due to judicial failure is beyond Commonwealth’s control; due diligence satisfied. |
Key Cases Cited
- Commonwealth v. Monosky, 511 Pa. 148 (Pa. 1986) (extension/Rule 1100 issue; judges' delay excusable under certain circumstances)
- Commonwealth v. Browne, 526 Pa. 83 (Pa. 1990) (due diligence requires DA to maintain simple tracking; scheduling responsibility shift clarified)
- Commonwealth v. Selenski, 606 Pa. 51 (Pa. 2010) (rule 600(diligence) standard; abuse-of-discretion standard on appeal)
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (speedy trial standard balancing factors; framework for States)
- Commonwealth v. Hamilton, 449 Pa. 297 (Pa. 1972) (establishing Rule 1100 mechanism to define speedy trial period)
- Commonwealth v. Meadius, 582 Pa. 174 (Pa. 2005) (context on Rule 600 and speedy trial protections)