State v. Crawford
In State v. Crawford, 202 Conn. 443, 521 A.2d 1034 (1987) the Court addressed whether the issuance of an arrest warrant before the statute of limitations expired tolled the running of the statute. In a footnote, the court, noting that it was not an issue before it, addressed the decision of the Appellate Session of the Superior Court in Cordova. Id., 452 n.13.
The Court recognized that the holding in State v. Cordova that the issuance of an arrest warrant, in and of itself, triggers a defendant's sixth amendment right to a speedy trial "does not comport with the purpose of the sixth amendment." Id.
The court stated: "The speedy trial guarantee is designed to minimize the possibility of lengthy incarceration prior to trial, to reduce the lesser, but nonetheless substantial, impairment of liberty imposed on an accused while released on bail, and to shorten the disruption of life caused by arrest and the presence of unresolved criminal charges." Id., 452-53 n.13.
The court also stated that the decision in State v. Cordova was inconsistent with General Statutes 54-82m, our speedy trial statute, noting that it does not place any significance on the date the arrest warrant was issued for determining when a defendant's sixth amendment right to a speedy trial attaches. State v. Crawford, supra, 453 n.13.