State v. Tate, 276 P.3d 1017

bondsman posted a $6,500 surety bond for Tate on June 1, 2009.
Tate failed to appear on January 25, 2010; the court ordered forfeiture and issued an arrest warrant.
notice of the order and judgment of forfeiture was mailed to Bradford on February 22, 2010.
59 O.S. § 1332(C) required the bondsman to return Tate within 90 days; if not, § 1332(D)(1) required deposit of the face amount within 91 days.
Bradford deposited the bond with the court clerk on the 92nd day after receipt of notice; Tate was returned to custody on June 3, 2010; remitter motion filed June 8, 2010.
The trial court granted remitter; the State appealed; the Court of Civil Appeals affirmed; the Supreme Court reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is 91-day deposit a condition precedent to remitter?	State: deposit by day 91 is required to seek remitter.	Bradford: remitter may be sought despite 92nd-day deposit.	Yes; deposit by day 91 is a condition precedent to remitter.
What if deposit occurs on the 92nd day?	State: remitter not available when deposit is late.	Bradford: late deposit should not foreclose remitter per statute.	Late deposit is not sufficient to obtain remitter.
Should the Court strictly interpret the remitter provisions given legislative history?	State: statutory alignment and history require strict adherence to deadlines.	Bradford: flexibility to achieve remitter exists under broader remedial language.	Court strictly interprets remitter provisions; timely deposit is mandatory.

State v. Van Lear, 813 P.2d 555 (1991 OK CIV APP) (addressed timing of receipt and deposits in remitter context)
State v. Wallace, 940 P.2d 1212 (1997 OK CIV APP) (remitter timing limits applied to filing window)
State v. Eubanks, 132 P.3d 641 (2006 OK CIV APP) (remitter treated as preconditioned by statute; timing matters)
State v. Anderson, 247 P.3d 294 (2011 OK CIV APP) (legislative history supports distinct prepayment and postpayment remedies)