State v. Franklin, 126 So. 3d 663

District attorney appeals trial court's grant of motion to quash the bill of information charging Franklin with bail jumping under La. R.S. 14:110.1 A.
Franklin allegedly failed to appear at a court date; he contends nonappearance was unintentional due to hospitalization August 18–26, 2011.
Trial court relied in part on medical documents attached to the motion to quash to support a merits-based defense.
Appellate review is de novo; motions to quash are limited to questions of law and should not consider factual merits.
The court noted that a defendant may have a meritorious defense on the merits, but this does not justify quashing the bill of information.
The court held that the trial court improperly considered factual defenses and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did trial court err by considering merits-based factual defenses on a motion to quash?	State argues court limited to legal questions only.	Franklin contends evidence supports unintentional missing due to hospitalization.	Yes; improper factual consideration requires reversal.
Is specific intent an element that requires factual proof at trial rather than quashing the information?	DA contends the bill adequately informs of charges; merits for trial.	Franklin asserts lack of intent negates offense; medical records could prove absence of intent.	Specific intent is a merit issue to be resolved at trial; quash not appropriate on that basis.

State v. Carter, 88 So.3d 1181 (La. App. 4 Cir. 2012) (motion to quash limited to pretrial pleas, not merits)
State v. Byrd, 708 So.2d 401 (La. 1998) (scope of motions to quash; absence of grounds requires different handling)
State v. Rembert, 312 So.2d 282 (La.1975) (limits on quashable issues; does not reach merits)
State v. Clark, 117 So.3d 1246 (La. 2013) (pretrial rulings; legal vs. factual considerations)
State v. Schmolke, 108 So.3d 296 (La. App. 4 Cir. 2013) (trial court's review of motion to quash confined to questions of law)