People v. HAJJAJ
117 Cal. Rptr. 3d 327
| Cal. | 2010Background
- Hajjaj was charged in Riverside Superior Court with selling/transferring a controlled substance; enhancement for prior conviction; additional prior-term penalty.
- Last-day deadline under Penal Code section 1382; extensive continuances due to courtroom unavailability and congestion.
- Judge determined there were no available courtrooms or judges on the last permissible day; defendants and counsel remained ready.
- Indio branch courtroom became available late; distances and timing prevented bringing case to trial that day.
- Trial court dismissed the case under section 1382; People refiled then appealed; Court of Appeal affirmed dismissal on differing grounds.
- Supreme Court of California reversed, holding that the late-available Indio court and travel constraints did not establish good cause to delay beyond the statutory period.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Hajjaj brought to trial within 60 days without waiver? | People argued good cause existed due to court congestion and late Indio availability. | Hajjaj was not brought to trial within 60 days; delays were unexcused and caused by state congestion. | No; dismissal proper unless good cause shown, and here no good cause established. |
| Did the late availability of the Indio courtroom constitute good cause for delay? | Court congestion plus late availability could justify delay. | Geographic remoteness and temporary availability do not constitute good cause. | No; physical remoteness and chronic congestion do not constitute good cause under 1382. |
| Could the delay be avoided by transferring to civil or other branch courts? | Transferring to civil or Indio divisions could have avoided dismissal. | Court administration had limited resources; not feasible to reassign to distant facilities. | Not accepted; such transfers do not provide good cause where unavailable to the defendant and counsel. |
| Does chronic court congestion in Riverside County defeat 1382 good-cause analysis as a constitutional violation? | Engram permits consideration of chronic congestion as good cause. | Chronic congestion cannot be used to routinely extend the statutory period. | Chronic congestion is not good cause; state must provide adequate resources. |
| What standard governs a good-cause determination under 1382? | Discretion should allow delays when resources are strained. | Court must consider totality and avoid artificial delays; defendant's presence and readiness are required. | Court has broad discretion but cannot rely on chronic congestion to justify delay; must consider total circumstances. |
Key Cases Cited
- Rhinehart v. Municipal Court, 35 Cal.3d 772 (Cal. 1984) (defines 'brought to trial' and重点 on readiness and swearing jurors)
- Sanchez v. Municipal Court, 97 Cal.App.3d 806 (Cal. App. 1979) (expands 'brought to trial' analysis to availability and good faith start)
- Amati v. Municipal Court, 63 Cal.App.3d Supp. 10 (Cal. App. 1976) (good-faith start to jury selection on last day)
- Johnson v. Superior Court, 26 Cal.3d 557 (Cal. 1980) (unavailability of resources is not always good cause; general rule on delays)
- Engram v. Superior Court, 50 Cal.4th 1131 (Cal. 2010) (congestion in Riverside not good cause; state must provide resources)
- Sutton v. Superior Court, 48 Cal.4th 533 (Cal. 2010) (good-cause considerations in 1382; balancing factors)
- Jackson v. Superior Court, 230 Cal.App.3d 1391 (Cal. App. 1991) (state responsibility for timely transport; logistical problems)