Russell v. Anchorage

In Russell v. Anchorage, 626 P.2d 586 (Alaska App. 1981) the defendant failed to appear for trial and was not arrested until several months later. The Court held that the Rule 45 clock should be reset, making the day of Russell's re-arrest a new Day 1, because of the following three factors: (1) the defendant intentionally failed to appear for court; (2) his disappearance was followed by a substantial period of absence; (3) by virtue of the defendant's inaction, no progress was made in the normal pretrial process before the defendant's disappearance. Id. at 590.